Gummadi Usha Rani v. Sure Mallikarjuna Rao
“Supreme Court Declares Trial Court's Reliance on AI-Generated Fake Judgments as Misconduct, Not Mere Error”
TL;DR
In a property dispute where an Andhra Pradesh trial court dismissed objections to an advocate commissioner's report by relying on four entirely fabricated AI-generated Supreme Court judgments, the Supreme Court took serious cognisance and declared that citing non-existent fake judgments constitutes judicial misconduct, not a mere adjudicatory error. The Court issued notices to the Attorney General, Solicitor General, and Bar Council of India, appointed Senior Advocate Shyam Divan as amicus curiae, and stayed the trial court from proceeding on the basis of the tainted advocate commissioner's report.
The Bottom Line
The Supreme Court ruled that a judicial decision founded on AI-generated fake judgments is not an error in decision-making but constitutes misconduct with legal consequences, sounding an institutional alarm about unchecked AI use in the judiciary.
Case Timeline
The journey from FIR to Supreme Court verdict
Civil Suit Filed
Respondents filed O.S. No. 773 of 2019, a civil suit for injunction relating to the disputed property in Andhra Pradesh
Civil Suit Filed
Respondents filed O.S. No. 773 of 2019, a civil suit for injunction relating to the disputed property in Andhra Pradesh
CRP for Advocate Commissioner
Petitioners obtained C.R.P. No. 1658 of 2023 from the High Court, setting aside trial court's rejection of the application for appointment of an advocate commissioner
CRP for Advocate Commissioner
Petitioners obtained C.R.P. No. 1658 of 2023 from the High Court, setting aside trial court's rejection of the application for appointment of an advocate commissioner
Advocate Commissioner's Report Filed
The advocate commissioner inspected the disputed property and submitted a report dated 8 July 2025
Advocate Commissioner's Report Filed
The advocate commissioner inspected the disputed property and submitted a report dated 8 July 2025
Trial Court Dismisses Objections Using AI-Generated Fake Judgments
The trial court dismissed the petitioners' objections to the advocate commissioner's report (I.A. No. 457 of 2025), citing four non-existent AI-generated Supreme Court judgments
Trial Court Dismisses Objections Using AI-Generated Fake Judgments
The trial court dismissed the petitioners' objections to the advocate commissioner's report (I.A. No. 457 of 2025), citing four non-existent AI-generated Supreme Court judgments
High Court Revision Petition Filed
Petitioners filed C.R.P. No. 2487 of 2025 before the Andhra Pradesh High Court challenging the trial court order
High Court Revision Petition Filed
Petitioners filed C.R.P. No. 2487 of 2025 before the Andhra Pradesh High Court challenging the trial court order
High Court Dismisses Revision Petition
Justice Ravi Nath Tilhari dismissed the revision petition, holding that AI-generated fake citations do not vitiate an order if the underlying law applied is correct
High Court Dismisses Revision Petition
Justice Ravi Nath Tilhari dismissed the revision petition, holding that AI-generated fake citations do not vitiate an order if the underlying law applied is correct
Supreme Court Takes Cognisance
The Supreme Court declared reliance on AI-generated fake judgments as misconduct, issued notices to the Attorney General, Solicitor General, and Bar Council of India, and appointed amicus curiae
Supreme Court Takes Cognisance
The Supreme Court declared reliance on AI-generated fake judgments as misconduct, issued notices to the Attorney General, Solicitor General, and Bar Council of India, and appointed amicus curiae
The Story
The dispute arose from a civil suit for injunction (O.S. No. 773 of 2019) filed by the respondents (Sure Mallikarjuna Rao and another) against the petitioners (Gummadi Usha Rani and another) relating to a property in Andhra Pradesh. During the pendency of the suit, the respondents sought appointment of an advocate commissioner to inspect and document the physical features of the disputed property.
The trial court initially rejected the application for appointment of an advocate commissioner. The petitioners then obtained a Civil Revision Petition (C.R.P. No. 1658 of 2023) from the High Court, which set aside the rejection and directed appointment of an advocate commissioner. The advocate commissioner inspected the property and submitted a report dated 8 July 2025.
The petitioners (defendants in the suit) challenged the advocate commissioner's report by filing I.A. No. 457 of 2025 under Section 151 CPC, seeking to set aside the report on grounds of alleged collusion and non-compliance with the court's directions, including the failure to take assistance from a Town or Mandal Surveyor.
On 19 August 2025, the trial court dismissed the petitioners' objections and accepted the advocate commissioner's report as part of the record. In doing so, the trial court cited four Supreme Court judgments to support its reasoning. However, upon subsequent verification, all four cited judgments turned out to be entirely fabricated — non-existent case laws that appeared to have been generated by an artificial intelligence tool. The trial judge later acknowledged that an AI tool had been used for the first time in drafting the order and that the cited judgments could not be authenticated in any official legal database.
The petitioners challenged the trial court's order before the Andhra Pradesh High Court through Civil Revision Petition No. 2487 of 2025. Justice Ravi Nath Tilhari of the High Court examined the matter and, while acknowledging that the citations were AI-generated fabrications, held that merely mentioning non-existent citations does not vitiate an order if the underlying legal principles applied are correct. The High Court dismissed the revision petition on merits, issuing a cautionary note regarding unregulated use of AI tools in legal research.
Aggrieved by the High Court's dismissal, the petitioners approached the Supreme Court through a Special Leave Petition. The Supreme Court bench of Justices P.S. Narasimha and Alok Aradhe took a markedly different and more serious view, declaring that reliance on fake AI-generated judgments is not a mere error but constitutes misconduct warranting legal consequences.
Legal Issues
Click each question to reveal the Supreme Court's answer
Arguments
The battle of arguments before the Supreme Court
Petitioner
Vihaan Kumar
Trial court relied on entirely fabricated judgments
The petitioners contended that the four Supreme Court judgments cited by the trial court in its order dated 19 August 2025 — Subramani v. M. Natarajan (2013) 14 SCC 95, Chidambaram Pillai v. SAL Ramasamy (1971) 2 SCC 68, Lakshmi Devi v. K. Prabha (2006) 5 SCC 551, and Gajanan v. Ramdas (2015) 6 SCC 223 — were non-existent and could not be verified in any official law reports or legal databases.
Decisions founded on fake authorities are fundamentally vitiated
The petitioners argued that a judicial order anchored on fabricated precedents is void ab initio, as it undermines the very foundation of the adjudicatory process. Judicial legitimacy depends upon authentic precedent, and reliance on synthetic authorities destroys public confidence in the justice system.
High Court failed to address systemic implications
The petitioners submitted that while the Andhra Pradesh High Court acknowledged the AI-generated nature of the citations, it failed to adequately address the systemic implications of allowing such conduct to go without consequence, merely issuing a cautionary note while upholding the tainted order.
Respondent
State of Haryana
Substantive legal conclusion was sound despite flawed citations
The respondents argued that even if the specific citations were flawed, the substantive legal conclusion reached by the trial court regarding the advocate commissioner's report remained legally sound. The report constituted evidence to be weighed at trial and its acceptance was procedurally appropriate.
Procedural lapses do not automatically void judicial orders
The respondents contended that courts should distinguish between inadvertent errors in citation and deliberate misconduct. Procedural lapses in referencing authorities do not automatically void orders if the underlying reasoning and legal principles applied are defensible.
AI tool usage creates margin for unintentional mistakes
The respondents submitted that AI tool usage in legal research inevitably creates some margin for unintentional mistakes and that the trial judge's first-time use of AI tools was an inadvertent error, not a deliberate act of misconduct.
Court's Analysis
How the Court reasoned its decision
The Supreme Court treated the case as raising an issue of considerable institutional concern that goes beyond the merits of the underlying property dispute. The Court drew a sharp distinction between adjudicatory errors — where a judge misinterprets or misapplies existing law — and misconduct — where a judge relies on fabricated legal authorities. The bench rejected the Andhra Pradesh High Court's position that fake citations can be overlooked if the underlying law applied is correct, holding that the integrity of the adjudicatory process demands that judicial decisions be grounded in authentic, verifiable precedents. By issuing notices to the highest law officers of the country and appointing an amicus curiae, the Court signalled its intent to develop a comprehensive framework governing AI use in the judiciary, addressing both accountability for past lapses and safeguards against future ones.
A decision based on such non-existent and fake alleged judgments is not an error in the decision making. It would be a misconduct and legal consequence shall follow.
The central holding of the case, establishing that reliance on fabricated precedents is categorically different from and more serious than ordinary adjudicatory errors, attracting consequences beyond mere appellate correction.
We take cognizance of the Trial Court deploying AI generated non-existing, fake or synthetic alleged judgments.
The Court's use of the term "cognizance" signals that this is being treated as a matter requiring institutional intervention, not merely an appeal on merits.
Reliance on fabricated or synthetic judgments undermines the integrity of the adjudicatory process.
Establishes that the harm caused by fake citations goes beyond the specific case and strikes at the foundational integrity of the judicial system as a whole.
AI systems can produce responses that appear persuasive yet are factually or legally incorrect.
The Andhra Pradesh High Court's observation (endorsed by the Supreme Court's institutional concern) acknowledging the specific danger of AI hallucinations — outputs that appear authoritative but are entirely fabricated.
The Verdict
Relief Granted
Trial court restrained from proceeding on the advocate commissioner's report. Institutional proceedings initiated to develop guidelines and accountability framework for AI use in judicial decision-making.
Directions Issued
- Notice issued in the Special Leave Petition returnable for further hearing
- Trial Court shall not proceed on the basis of the Advocate Commissioner's Report during the pendency of the proceedings
- Notice issued to the Attorney General of India to assist the Court
- Notice issued to the Solicitor General of India to assist the Court
- Notice issued to the Bar Council of India regarding the institutional implications
- Senior Advocate Shyam Divan appointed as amicus curiae to assist the Court in examining the institutional ramifications of AI-generated content in judicial orders
- Permission granted to the amicus curiae to nominate an Advocate-on-Record for assistance
- Matter listed for comprehensive examination of responsible AI usage within the Indian legal system
Key Legal Principles Established
A judicial decision founded on AI-generated, non-existent fake judgments constitutes misconduct, not a mere adjudicatory error.
Judges are duty-bound to independently verify all legal authorities before placing reliance on them in judicial orders.
While AI may assist legal research, it cannot substitute careful judicial scrutiny and independent verification of cited precedents.
The integrity of the adjudicatory process requires that judicial decisions be grounded in authentic, verifiable legal authorities.
Citing AI-generated fake judgments is fundamentally different from misapplying authentic law — the former is misconduct, the latter is error subject to appellate correction.
Attributing fabricated quotes or principles to real or imaginary judgments amounts to deception of the court.
The use of unverified AI tools for drafting judicial orders without human oversight constitutes professional negligence.
Key Takeaways
What different people should know from this case
- If you receive an unfavourable court order, you can challenge it by verifying whether the judgments cited by the court actually exist in official legal databases.
- Courts cannot base their decisions on fake or AI-generated judgments. If they do, it is treated as misconduct by the Supreme Court, not just an honest mistake.
- The Supreme Court is actively working to ensure that AI tools used by judges and lawyers do not compromise the fairness and integrity of court proceedings.
- You have the right to expect that every judgment cited against you in a court order is a real, verifiable decision of a real court.
Legal Framework
Applicable laws and provisions
Constitutional Provisions
Article 136
Constitution of India
“Special leave to appeal by the Supreme Court. Notwithstanding anything in this Chapter, the Supreme Court may, in its discretion, grant special leave to appeal from any judgment, decree, determination, sentence or order in any cause or matter passed or made by any court or tribunal in the territory of India.”
Relevance: The petitioners invoked Article 136 to file the Special Leave Petition before the Supreme Court challenging the Andhra Pradesh High Court's dismissal of their civil revision petition.
Article 227
Constitution of India
“Every High Court shall have superintendence over all courts and tribunals throughout the territories in relation to which it exercises jurisdiction.”
Relevance: The petitioners initially filed C.R.P. No. 2487 of 2025 under Article 227 before the Andhra Pradesh High Court, challenging the trial court's order that relied on AI-generated fake judgments.
Article 21
Constitution of India
“No person shall be deprived of his life or personal liberty except according to procedure established by law.”
Relevance: The right to a fair trial and due process is implicated when judicial decisions are based on fabricated authorities, as it denies litigants the procedural fairness guaranteed by the Constitution.
Statutory Provisions
Section 151
Code of Civil Procedure, 1908
“Nothing in this Code shall be deemed to limit or otherwise affect the inherent power of the Court to make such orders as may be necessary for the ends of justice or to prevent abuse of the process of the Court.”
Relevance: The petitioners filed I.A. No. 457 of 2025 under Section 151 CPC seeking to set aside the advocate commissioner's report, which was the application dismissed by the trial court using AI-generated fake citations.
Order XXVI Rule 10
Code of Civil Procedure, 1908
“Provisions relating to the appointment of commissioners for local investigation, examination of accounts, making partitions, holding scientific or expert investigations.”
Relevance: The advocate commissioner was appointed under these provisions to inspect and document the physical features of the disputed property, and the validity of the commissioner's report was the central procedural issue before the trial court.
Section 35
Advocates Act, 1961
“Where on receipt of a complaint or otherwise a State Bar Council has reason to believe that any advocate on its roll has been guilty of professional or other misconduct, it shall refer the case for disposal to its disciplinary committee.”
Relevance: The notice to the Bar Council of India raises the question of professional responsibility of lawyers who submit AI-generated fake citations without verification, potentially attracting disciplinary proceedings.
Related Cases & Precedents
Mata Hari Mata Rani Sharma v. The State of AI (US)
similarNo. 22-cv-1461 (S.D.N.Y. 2023)
The US case of Mata v. Avianca, where a New York lawyer was sanctioned for submitting a brief containing entirely fabricated case citations generated by ChatGPT. This international parallel highlights the global nature of the AI hallucination problem in legal proceedings.
Bar Council of India v. A.K. Balaji
cited(2018) 5 SCC 379
Supreme Court case addressing the regulation of legal practice and professional standards for advocates, relevant to the question of lawyer accountability for submitting unverified AI-generated citations.
Common Cause v. Union of India
similar(2018) 5 SCC 1
A case where the Supreme Court addressed institutional reform and systemic issues in the justice system, similar to how the present case addresses the systemic challenge of AI use in judicial decision-making.
Swapnil Tripathi v. Supreme Court of India
similar(2018) 10 SCC 639
Supreme Court case dealing with technology and transparency in the judicial system through live-streaming of court proceedings, reflecting the judiciary's engagement with technological change.
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