The Supreme Court of India, while considering an SLP in Gummadi Usha Rani & Anr. v. Sure Mallikarjuna Rao & Anr, expressed serious displeasure over a trial court’s reliance on non-existent, allegedly Artificial Intelligence (AI)-generated case law. The Court added that such misconduct strikes at the very integrity of the adjudicatory process and cannot be brushed aside as a mere error of law.
Deployment of Non-existing AI-Generated Citations
The apex Court observed that the deployment of AI-generated, non-existing, fake, or synthetic judgments in judicial reasoning demands scrutiny. The issue, the Court held, goes beyond a mistaken appreciation of law:
“At the outset, we must declare that a decision based on such non-existent and fake alleged judgments is not an error in the decision-making process. It would be a misconduct and legal consequence shall follow.”
This strong articulation underscores the Court’s concern that reliance on fabricated precedents undermines public confidence in the judicial system. The Court indicated that consequences and accountability must follow where such conduct directly affects the integrity of adjudication.
The Trial Court’s Reliance on AI Generated Judgments
In the case under consideration, the trial court dismissed objections by relying on four purported decisions of the Supreme Court:
- 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
- Gajanan v. Ramdas (2015) 6 SCC 223
Upon scrutiny, it was revealed that the judgments as referred to by the trial court were Artificial Intelligence-generated and did not exist in the form relied upon.
The Supreme Court emphasised that the judicial function demands due diligence and verification, particularly in an era where generative AI tools can produce convincing but entirely fictitious legal content.
A Growing Concern: Fake AI Citations in Court Filings
This is not the first time the Supreme Court has confronted the issue of AI-generated legal fabrications.
On an earlier occasion, a Bench comprising Justice B.V. Nagarathna and Justice Ujjal Bhuyan raised the problem of lawyers submitting AI-drafted petitions containing fake case citations. During the proceedings, reference was made to a non-existent case titled “Mercy v. Mankind.”
Justice Nagarathna expressed serious concern and urged Supreme Court Bar Association President Vikas Singh, who was present in court, to take appropriate steps to address the emerging misuse of AI in legal drafting.
The Way Forward
The Court’s intervention reflects an institutional recognition that while AI tools may assist research and drafting, uncritical reliance on such tools—without independent verification—poses a serious risk to the administration of justice.
The unambiguous message is this: the technology may assist, but it cannot replace diligence, verification, and ethical responsibility. It reminds all stakeholders that the integrity of the adjudicatory process needs to be kept intact.
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