AI-Hallucinated Citations in Indian Courts: Case Tracker and Pre-Filing Checklist
As of 9 October 2026, the Supreme Court has said twice that citing unverified AI-generated precedents is misconduct, and has set aside two decisions built on them. The Bombay High Court has imposed ₹50,000 in costs for one non-existent case. Lawgix AI checked the six cases below against the orders themselves.
This tracker lists Indian court orders where fabricated or misdescribed authorities were found. Every row in the main table was read in the court's own order or judgment, not only in a news report. A second table lists cases we found in press reports but could not check against the order. We left them out of the main count.
Two things surprised us. In four of the six verified cases the fault lay with the adjudicator (a trial court, a tribunal, a tax officer, a customs officer), not with counsel. And one of the six orders does not mention AI at all. It only records that the precedents "do not even exist".
What are the key facts as of 9 October 2026?
| Fact | Status as of 9 Oct 2026 |
|---|---|
| Cases verified against the order | 6 (3 Supreme Court, 2 Bombay High Court, 1 Delhi High Court) |
| Supreme Court wording | Citing such judgments "is a misconduct on the part of an advocate" (Pooja Ramesh Singh, 2 July 2026) |
| Decisions set aside | 3: the NCLT and NCLAT orders in an insolvency case and a ₹425.27 crore customs penalty (both by the Supreme Court), and a tax assessment for AY 2023-24 (Bombay High Court). In Gummadi the Supreme Court barred reliance on a trial-court report pending the SLP |
| Costs imposed on a party | ₹50,000 (Bombay High Court, 7 Jan 2026) |
| Bar Council of India rule on AI-assisted drafting | None found. See what rules govern an advocate's use of AI |
| Supreme Court draft AI regulations | Still a draft. See the AI rules in Indian courts tracker |
Which Indian cases involve AI-hallucinated citations?
Six cases between September 2025 and September 2026, listed newest first. All six were read in the order or judgment.
| Date | Court and case | Who relied on the fake material | What was wrong | Outcome | Order |
|---|---|---|---|---|---|
| 2 Sept 2026 | Supreme Court, Vijay Ghanshyam Gadiya v. Union of India, 2026 INSC 947 (Datta and Nagu JJ) | Customs adjudicating authority (Order-in-Original of 8 Oct 2025) | Some cited cases were "non-existent or have fake citations"; others did not lay down the ratio attributed to them | Penalty of ₹425.27 crore and the Gujarat High Court order upholding it set aside; fresh decision by a different officer | Judgment PDF (LiveLaw copy) |
| 2 July 2026 | Supreme Court, Pooja Ramesh Singh v. J&K Bank Ltd., 2026 INSC 668 (Narasimha and Aradhe JJ) | NCLT and NCLAT | Three non-existent cases; two real cases cited with paragraphs that do not exist; one real judgment cited under the wrong case name | NCLT order of 28 Aug 2024 and NCLAT judgment of 11 Sept 2025 set aside; Section 7 application restored for fresh decision; BCI directed to form a committee | Judgment PDF (Verdictum copy) |
| 27 Feb 2026 | Supreme Court, Gummadi Usha Rani v. Sure Mallikarjuna Rao, SLP (C) 7575/2026 (Narasimha and Aradhe JJ) | Trial court (order of 19 Aug 2025) | Four Supreme Court decisions alleged to be non-existent. The High Court recorded that they were AI-generated and still decided the revision on merits | Notice issued; trial court not to proceed on the commissioner's report; notice to Attorney General, Solicitor General and BCI; Shyam Divan appointed to assist | Order PDF (Verdictum copy) |
| 7 Jan 2026 | Bombay High Court, Deepak v. Heart & Soul Entertainment Ltd., WP 8390/2009, 2026:BHC-AS:828 (Sathaye J) | Respondent, in written submissions | One case, "Jyoti w/o Dinesh Tulsiani Vs. Elegant Associates", cited with no citation or copy; the court and its law clerks could not find it | ₹50,000 costs to the High Court Employees Medical Fund within two weeks | Order PDF (Verdictum copy) |
| 6 Oct 2025 | Bombay High Court, KMG Wires Pvt. Ltd. v. National Faceless Assessment Centre, WP (L) 24366/2025 (Colabawalla and Jamsandekar JJ) | Assessing officer | "The judicial decisions relied upon are completely non-existent" (three decisions, not named in the order) | Assessment order of 27 Mar 2025 (AY 2023-24), demand notice and penalty notice quashed; remanded for a fresh hearing | Order PDF (LiveLaw copy) |
| 25 Sept 2025 | Delhi High Court, Greenopolis Welfare Association v. Narender Singh, CM(M) 1909/2025 (Kathpalia J) | Petitioner | Respondents said some precedents cited "do not even exist" and quoted portions do not exist. The order does not mention AI | Petition dismissed as withdrawn; no costs | Order PDF (Delhi High Court) |
Three notes on reading this table:
- The Supreme Court is careful with its words. In Gummadi it calls the judgments "alleged" and does not itself find them non-existent. In Gadiya it says the problem "appears to be a hallucination of AI". It does not state that the order was drafted with AI. In KMG Wires and Greenopolis the courts found the authorities did not exist, but say nothing about the tool that produced them.
- Costs have been rare so far. Only the Bombay High Court's ₹50,000 order imposes a penalty on a party. The Supreme Court has so far remanded and set aside rather than fined.
- The Greenopolis row shows why "AI" is not the test. The order records fabricated precedents and fabricated quoted passages. Whether the source was an AI tool is not stated. The filing duty is the same either way: the authority has to exist and say what you claim.
What has the Supreme Court said about advocates?
The Supreme Court has said citing such judgments is misconduct, and the duty falls on the advocate whether or not a BCI rule exists. Two orders make the point.
In Gummadi (27 Feb 2026), the Court said of reliance on the alleged judgments: "It would be a misconduct and legal consequence shall follow." In Pooja Ramesh Singh (2 July 2026), it held that "It is a misconduct on the part of an advocate to cite such judgments", and directed courts to adopt a "zero-tolerance mode" for producing, citing or using AI-generated precedents without verification.
The same judgment directs the Bar Council of India to constitute a committee on members submitting fake material as precedents. As of 9 October 2026 we found no BCI rule or committee report. Our post on the rules that govern an advocate's use of AI covers what binds advocates in the meantime.
What are the three ways AI gets a citation wrong?
AI errors in citations fall into three types, and all three appear in the orders above. Each needs a different check.
- The case does not exist. The name, the citation and the holding are all invented. Pooja Ramesh Singh lists three such cases with plausible SCC citations. KMG Wires and Heart & Soul are the same type. Check: look the case up by party name and by citation in a reliable database. If neither finds it, it is not safe to cite.
- The case exists but the paragraph does not. The judgment is real, the citation may even be correct, but the quoted paragraph or the proposition is invented. Pooja Ramesh Singh records two such cases, and the Greenopolis order records quoted portions that do not exist. Check: open the judgment and find the exact paragraph you cite.
- The case exists but is cited for the wrong point or under the wrong name. Gadiya records real cases that "did not lay down the ratio" attributed to them. Pooja Ramesh Singh records one real judgment cited under a different case title and citation. Check: read the holding, not the headnote, and match the reporter citation to the case name.
Type 1 is caught by a database lookup. Types 2 and 3 are not. A tool can return a real case name and still misstate what it decided, which is why the checklist below ends with a person reading the source.
What is a 7-step check before you file?
Run this check on every authority in every filing, whoever drafted it. The Supreme Court has made verification the filer's responsibility, and this is a practical way to do it.
- List every authority. Make a table of every case, statute and article cited, with the proposition each is cited for.
- Find each case in a database by party name and by citation. Do not rely on the AI tool's own link or summary.
- Open the judgment itself, not a headnote, a blog or an AI summary.
- Find the cited paragraph and compare each quoted word with the source. If you quote it, it must be there.
- Confirm the holding supports your point, including whether it was overruled, distinguished or limited to its facts.
- Match the citation to the case. Check the reporter, volume, page and court. In Pooja Ramesh Singh, one real judgment was cited under the wrong title.
- Record who checked what, and when. Keep a one-line note per matter: tool used, task, person who verified, date. If the Supreme Court's draft Regulation 43(3) is notified, you may have to declare AI use at filing.
If a step fails, remove the authority. Do not substitute a similar-sounding case without reading it.
Which cases did we find but not verify?
Two matters appear in press reports, but we could not check the underlying order. We list them for completeness and do not count them above.
| Matter | What was reported | Why not verified |
|---|---|---|
| ITAT Bengaluru, Buckeye Trust v. PCIT, ITA 1051/Bang/2024 (order of 30 Dec 2024) | Secondary sources say the order cited judgments that could not be found and was recalled in January 2025 | We did not retrieve the recall order. Our source (ITAT Online) confirms a recall under section 254(2) on 7 Jan 2025 but not the reason |
| Supreme Court, special leave petition by the director of Heart & Soul Entertainment (reported March 2026) | The Tribune reports a bench of Bindal and Bishnoi JJ called fake AI judgments a widespread problem and expunged a High Court remark on the petitioner | We did not retrieve the order |
How does this connect to the court rules?
The cases show what judges do when citations fail. The rules show what judges and advocates are told to do. Our AI rules in Indian courts tracker covers the Supreme Court draft, the Kerala, Gujarat and Punjab & Haryana High Court policies, and the BCI's position. Where this post and that one overlap, the tracker holds the rules and this post holds the cases.
Lawgix AI builds legal AI for Indian law firms, so we have a stake in how courts treat AI. The cases above are why we think research tools should show the source passage next to every answer, so a person can check it in seconds. See the Lawgix AI homepage for how we approach that. The tracker lists what courts have decided, whoever the vendor is.
Change log
| Date | Change |
|---|---|
| 9 Oct 2026 | First version. Six cases checked against the orders; two reported cases listed unverified |
Next scheduled re-check: 9 November 2026, or sooner if a new order is reported.
Sources
- Supreme Court of India, Vijay Ghanshyam Gadiya v. Union of India, 2026 INSC 947, 2 Sept 2026: https://www.livelaw.in/pdf_upload/2026/09/02/vijay-ghanshyam-gadiya-v-union-of-india-and-another-697691.pdf
- Supreme Court of India, Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd., 2026 INSC 668, 2 July 2026: https://www.verdictum.in/pdf_upload/2026/07/02/523382sc-1780293.pdf
- Supreme Court of India, order in SLP (C) 7575/2026, Gummadi Usha Rani v. Sure Mallikarjuna Rao, 27 Feb 2026: https://www.verdictum.in/pdf_upload/gummadi-usha-rani-anr--1772891.pdf
- Bombay High Court, order in WP 8390/2009, 7 Jan 2026: https://www.verdictum.in/pdf_upload/ordjud-41bom-hc-1765219.pdf
- Bombay High Court, order in WP (L) 24366/2025, KMG Wires Pvt. Ltd., 6 Oct 2025: https://www.livelaw.in/pdf_upload/kmg-wires-private-limited-627647.pdf
- Delhi High Court, order in CM(M) 1909/2025, 25 Sept 2025: https://delhihighcourt.nic.in/app/showFile/1758803716_72d19c3525b2f32e_608_19092025.pdf/2025
- ITAT Online, Buckeye Trust v. Registrar, ITAT: https://itatonline.org/digest/verdicts/buckeye-trust-v-registrar-itat/
- The Tribune, "Citing AI-generated fake judgments a worldwide menace: Supreme Court": https://www.tribuneindia.com/news/india/citing-ai-generated-fake-judgments-a-worldwide-menace-supreme-court/
- SCC Online, Bombay High Court costs of ₹50,000, 19 Jan 2026: https://www.scconline.com/blog/post/2026/01/19/bom-hc-cost-unverified-ai-generated-submissions/
Related
- What rules actually govern an Indian advocate's use of AI
- AI rules in Indian courts: 2026 tracker
- Legal AI pricing in India (2026)
- Lawgix AI
This is general information, not legal advice. Status as of 9 October 2026.