SC raps trial court for citing AI-generated orders in deciding case

The Supreme Court has taken a stern view of a trial court order that relied on judgments later found to be fictitious and possibly generated through artificial intelligence (AI) tools, observing that such conduct strikes at the heart of judicial integrity and cannot be treated as a mere error of reasoning. A Bench of Justices P S Narasimha and Alok Aradhe was hearing a special leave petition (SLP) arising from a civil revision decided by the Andhra Pradesh High Court.

 

“We take cognizance of the trial court deploying AI-generated non-existing, fake or synthetic alleged judgments, and seek to examine its consequences and accountability as it has a direct bearing on the integrity of the adjudicatory process," the Bench said.

 

 

The apex court further underscored that reliance on fabricated cases goes beyond an inadvertent mistake.

 

“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. It would be misconduct, and legal consequences shall follow," the Bench remarked.

 

The dispute arises from a suit for injunction filed by the respondents. During the pendency of the suit, the trial court appointed an advocate commissioner to record the physical features of the property in question. The defendants objected to the commissioner’s report. However, by an order dated August 19, 2025, the trial court rejected their objections.

 

While dismissing the challenge, the trial court relied on four purported Supreme Court decisions, including 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.

 

The defendants contended before the High Court that these cited cases were “non-existent and fake orders". The High Court examined the contention and found that the judgments referred to in the trial court’s order were not traceable and appeared to be AI-generated.

 

While placing on record a word of caution about the unverified use of AI-generated material in judicial orders, the High Court nonetheless proceeded to decide the civil revision on merits and affirmed the trial court’s ruling. Challenging this, the defendants approached the top court.

 

The Bench observed that the matter raised “considerable institutional concern”, clarifying that the anxiety of the court was not about the substantive correctness of the outcome but about “the process of adjudication and determination". The apex court indicated that it would undertake a detailed examination of the consequences and accountability arising from a judicial order founded on fabricated precedents.

 

In view of the broader ramifications, the Bench issued notice to the Attorney General for India, the Solicitor General of India, and the Bar Council of India. Senior advocate Shyam Divan has been appointed as amicus curiae to assist the court, with liberty to nominate an advocate-on-record for further assistance. Recently, the Supreme Court had expressed concerns over lawyers citing AI-generated fake cases in pleadings. 

Legal lapse 

• Supreme Court calls issue a serious institutional concern
• Court says fake citations undermine credibility of adjudicatory process
• High court cautioned against unverified use of AI material
• Defendants challenged trial court order before the court
• Advocate commissioner appointed to record property’s physical features
• Court to examine accountability for AI-based judicial lapses