AI-invented citations in Indian courts: the register
By Abhijeet, founder, Pundora · Published 3 October 2026
On 2 July 2026 the Supreme Court held that citing a judgment without verifying it is misconduct on the part of an advocate. This is a plain record of every Indian order on the subject that could be traced: 21 entries, 14 of them read in the order itself, newest first.
The ruling that changed the question
"It is a misconduct on the part of an advocate to cite such judgments without verification."Pooja Ramesh Singh v. Jammu & Kashmir Bank Ltd, 2026 INSC 668, Supreme Court of India, 2 July 2026 (Supreme Court Observer's law report; source below).
The Court set aside orders that rested on judgments which did not exist, spoke of zero tolerance for the production, citation or reliance upon AI-generated precedents without independent verification, and directed the Bar Council of India to frame guiding principles and the disciplinary consequences. The entries below are the orders before and after it.
How to read this register
One entry per order or judgment, newest first. Each links to the document where one could be found, and to a report of it.
The wording is neutral. Advocates and parties are not named here unless the court's own title names them; the point is what courts have done, not who erred.
An entry marked as not verified could not be traced to the court's document or a full report when this was compiled; it is listed so that it can be found, and it says so.
A missing order is a gap, not a claim that none exists. Write to contact@pundora.in with the order and it will be added, dated and credited to the document.
What the record shows
16 orders and hearings between 30 December 2024 and 2 September 2026 that dealt with citations or passages which do not exist (two of them, in the Andhra Pradesh High Court and the Supreme Court, arise from one trial-court order).
In 13 of them the invented material was in an order of a court, a tribunal or a tax authority itself, not in an advocate's filing. The problem is not only at the Bar.
Costs were imposed once in this record (Rs 50,000, Bombay High Court, January 2026, on a party appearing in person). Far more often the order was set aside or recalled, or the matter sent back.
14 of the 21 entries were read in the order or judgment itself; the rest are marked.
The incidents, newest first
Supreme Court of India — 2 September 2026
Matter
Vijay Ghanshyam Gadiya v. Union of India & Anr, Civil Appeal arising out of SLP (C) No. 15605 of 2026; 2026 INSC 947
Who relied on it
quasi-judicial authority
What was wrong
'case laws that are either non-existent or have fake citations', plus real cases that 'do not lay down the ratio deduced therefrom and it appears to be a hallucination of AI'; counts not given.
What the court did
High Court order and Order-in-Original set aside; proceedings revived before a different officer of the same rank; appointing authority left free to act against the author of the order
In the court's words
"AI may well serve as training wheels but entrusting it with the pilot's seat would be both imprudent and dangerous."
Faiz Enterprise through Proprietor Mahetar Mahir Farukbhai v. State Tax Officer, Unit-67, Surat & Anr, R/Special Civil Application No. 10123 of 2026; 2026 LiveLaw (Guj) 228
Who relied on it
quasi-judicial authority
What was wrong
'State of Gujarat v. Aarbee Structures Pvt. Ltd., 2024 (4) TMI 951' (does not exist); 'M/s. Sri Vinayaga Agencies v. Assistant Commissioner, 2023 (5) TMI 106' (different citation and ratio); 'Jyoti Tar Products Pvt. Ltd. v. Deputy Commissioner, 2024 (7) TMI 512' (matches nothing). Court: order passed 'by placing reliance exclusively on the AI generated case laws'.
What the court did
SCN (30.10.2025), cancellation order (15.12.2025), revocation rejection (10.03.2026) and appellate order (25.05.2026) quashed; department's instructions of 18.08.2026 on verifying AI-sourced case law incorporated; violation 'would amount to contempt of this Court'
In the court's words
"the impugned order has been passed by the State Tax Officer by placing reliance exclusively on the AI generated case laws."
Employees Provident Fund Organization, Regional Office Delhi (South) v. Principal Commissioner of Income Tax, Delhi & Anr, W.P.(C) 6049/2026 & W.P.(C) 6051/2026; 2026 TAXSCAN (HC) 1109 (per Taxscan)
Who relied on it
quasi-judicial authority Brij Lal Meena, Addl./JCIT-2 Jaipur, since retired; order 24.02.2026; said citations came from his Inspector and were inserted 'without verifying')
What was wrong
Six non-existent judgments: CIT v. Outstanding Industrial Enterprises (2002) 256 ITR 466 (Del); CIT v. Orissa Corporation (P) Ltd (2007) 7 SCC 229; CIT v. Jayachandran Textile Mills (2019) 413 ITR 244 (SC); CIT v. Veerabhadrappa & Sons (2000) 245 ITR 232 (SC); CIT v. Sree Meenakshi Mills Ltd (2004) 267 ITR 337 (SC); CIT v. Oswal Agro Mills Ltd (2008) 304 ITR 1 (SC). 'We have called/summoned above books and to our utter surprise, none of the cited judgments exist.'
What the court did
CIT(A) order set aside and remanded; no disciplinary direction because the author had retired; court says strict action including disciplinary action should follow in future
In the court's words
"Any order which is edified on any order/judgment which does not exist, is a nullify and amounts to fraud upon the justice delivery system."
Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd & Anr, Civil Appeal No. 11950 of 2025; 2026 INSC 668; 2026 SCC OnLine SC 1258; 2026 LiveLaw (SC) 653; 2026 SCO.LR 7(2)[6]
Who relied on it
the tribunal itself No. 1808/2024)
What was wrong
Six citations: three non-existent (ICICI Bank v. Urban Infrastructure Real Estate (2019) 16 SCC 528; V.S. Dempo & Co. v. Reliance Communications (2021) 10 SCC 176; Sarbjit Singh v. Union Bank of India (2022) 7 SCC 464) and three real judgments with invented paragraphs (SBI v. Shree Ram Urban Infrastructure 2020 SCC OnLine SC 341 - actually M. Subramaniam v. S. Janaki (2020) 16 SCC 728; Everest Kento Cylinders (2015) 2 SCC 1; Canara Bank v. N.G. Subbaraya Setty (2018) 16 SCC 228).
What the court did
NCLT and NCLAT orders set aside; s.7 application restored for fresh decision; Bar Council of India directed to constitute a committee, prescribe a guiding principle and the disciplinary action for violations; zero tolerance declared for Bar and Bench
In the court's words
"It is a misconduct on the part of an advocate to cite such judgments without verification."
High Court of Jammu & Kashmir and Ladakh, Srinagar — 6 June 2026
Matter
Principal, Woodland House School & Ors v. Shakeel Ahmad Malik, CM(M) 191/2026; 2026 LiveLaw (JKL) 257
Who relied on it
the trial court; AI use inferred, not found
What was wrong
Two principal citations incorrect: one title 'could not be traced despite diligent search' and 'does not appear to exist in the form in which it has been referred to'; the other a real decision with a 'patently incorrect' citation.
What the court did
Petition dismissed, trial court order upheld on merits; judicial officers cautioned; judgment circulated to all judicial officers through the Registrars Judicial
In the court's words
"Any proposition of law, citation, extract, or precedent generated or suggested by an artificial intelligence tool must be independently verified from authentic and authoritative sources before being relied upon in a judicial order."
Delhi High Court (appeal from District Judge (Commercial)-02, South-East, Saket Courts) — 30 April 2026
Matter
SNV Aviation Pvt Ltd (Akasa Air) v. ABS Tour and Travels, RFA(COMM) 284/2026 (impugned: CS(Comm) 322/2024, judgment 24.02.2026)
Who relied on it
the trial judge-02) (alleged)
What was wrong
Alleged 'non-existent propositions of law attributed to actual case laws' of the Supreme Court; appellant's authorities 'distinguished using artificial intelligence softwares' (appellant's chart). High Court: prima facie impression of AI use, not conclusive.
What the court did
Notice issued; Rs 1,08,80,000 decree stayed on deposit of Rs 20 lakh by 30.05.2026; trial court record requisitioned; listed 20.08.2026 (result not found)
In the court's words
"The manner of drafting and the manner in which the text distinguishing the case laws is set out in the impugned judgement, prima facie, gives an impression that there is some AI softwares which may have been used for the same."
Gummadi Usha Rani & Anr v. Sure Mallikarjuna Rao & Anr (cognisance of a trial court using AI-generated judgments), SLP (C) No. 7575/2026 (Diary No. 6571/2026); 2026 SCC OnLine SC 341 (per SCC Online blog)
Who relied on it
the trial court; SC took cognisance
What was wrong
The four non-existent Supreme Court citations listed in para 2 of the order (Subramani; Chidambaram Pillai; Lakshmi Devi; Gajanan).
What the court did
Notice returnable 10.03.2026; trial court not to proceed on the Advocate Commissioner's report; notice to the Attorney General, Solicitor General and Bar Council of India; Shyam Divan Sr. Adv. appointed to assist. 5 May 2026: BCI asked to constitute a committee of independent experts and file a report; listed 26 May 2026 (later hearings not traced).
In the court's words
"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."
City Civil and Sessions Court, Bengaluru — 27 January 2026
Matter
Gayathri v. Guru Reddy @ S.N. Raju & Ors, O.S. No. 4956/2011
Who relied on it
the court itself
What was wrong
No fake citation identified; chatbot residue left inside the judgment text (offers to 'Tighten the language', 'Prepare a separate decree sheet', 'Just say the word'; 'Here is a clear, court-style discussion...').
What the court did
Charlotin's CSV: 'Judgment later revoked' - UNVERIFIED; OfficeChai (26 Sep 2026) reports no known consequence
In the court's words
"If you want, I can: Tighten the language further to match a specific Karnataka civil court style"
Andhra Pradesh High Court, Amaravati — 21 January 2026
Matter
Gummadi Usha Rani & Anr v. Sure Mallikarjuna Rao & Anr, Civil Revision Petition No. 2487 of 2025
Who relied on it
the trial court; the judicial officer reported first-time use of an AI tool, in good faith
What was wrong
Four Supreme Court citations: Subramani v. M. Natarajan (2013) 14 SCC 95; Chidambaram Pillai v. SAL Ramasamy '(1071) 2 SCC 68'; Lakshmi Devi v. K. Prabha (2006) 5 SCC 551; Gajanan v. Ramdas (2015) 6 SCC 223.
What the court did
Revision dismissed; trial court's report accepted; order held not vitiated; 'word of caution' on AI (advocateprakhar's 'order quashed; notice to judicial officer' is wrong)
In the court's words
"Merely because non-existing citations were referred due to the use of Artificial Intelligence Tool, without due verification, the order would not be vitiated, when the law stated in the order and its application is correct"
Deepak s/o Shivkumar Bahry v. Heart & Soul Entertainment Ltd, Writ Petition No. 8390 of 2009 with Interim Application No. 6969 of 2025; 2026:BHC-AS:828; 2026 SCC OnLine Bom 209
Who relied on it
party in person
What was wrong
One non-existent case 'Jyoti w/o Dinesh Tulsiani Vs. Elegant Associates' (no citation, no copy) in written submissions bearing 'give-away features, such as green-box tick-marks, bullet-point-marks, repetitive submissions'.
What the court did
Costs Rs 50,000 payable to the High Court Employees Medical Fund within two weeks; perjury/contempt application dismissed; warning that an advocate doing this may be referred to the Bar Council
In the court's words
"If an advocate is found to be indulging in such practice, then even stricter action of referring to Bar Council may follow."
Omkara Assets Reconstruction Pvt Ltd v. Gstaad Hotels Pvt Ltd (rejoinder of promoter Deepak Raheja)
Who relied on it
party / litigant's rejoinder filed through counsel
What was wrong
Alleged by Sr. Adv. Neeraj Kishan Kaul: 'over a hundred' / 'hundreds' of citations that 'do not exist at all', including criminal rulings passed off as insolvency precedents.
What the court did
Oral warning (court would 'put the appellant to task' if AI-generated); withdrawal of the tainted submission permitted; no costs or sanction reported; appeal heard on merits
In the court's words
"I have never been more embarrassed"
Read it
primary document not located · a report of it · from a compilation or a search result only; not read at source
Delhi High Court — 18 November 2025
Matter
MS J M Jain Prop. Sh Jeetmal Choraria v. Union of India & Ors, W.P.(C) 16754/2025; 2025:DHC:10505-DB
Who relied on it
quasi-judicial authority
What was wrong
'Surjeet Singh Chhabda v. Union of India (1997) 223 ITR 506 (SC)' non-existent (that citation is Neela Production v. CIT); 'Kishan Lal v. Union of India (2003) 258 ITR 359 (Del HC)' wrong (actual: CIT v. Kishan Lal (HUF)); one of three citations correct. Court called for the physical books from the High Court library.
What the court did
Warning to the Department; writ petition dismissed and show-cause notice sustained (advocateprakhar's 'SCN set aside' is contradicted)
In the court's words
"there is a clear possibility of the citations themselves being fake, as is clear from one of the judgments, which is cited in the present SCN."
Greenopolis Welfare Association v. Narender Singh & Ors, CM(M) 1909/2025, CM APPL. 61371-61372/2025
Who relied on it
advocate / petitioner's side
What was wrong
Non-existent 'Chitra Narain v. DDA, 2000 (87) DLT 276'; quoted paragraphs 73-74 of Raj Narain v. Indira Nehru Gandhi (1972) 3 SCC 850, which has 27 paragraphs; misquoted para 21 of Dalip Singh v. State of U.P. (2010).
What the court did
Dismissed as withdrawn; order records that some precedents 'do not even exist' and quoted portions 'do not exist'; respondents to 'take appropriate steps'; no costs recorded
In the court's words
"some of the judicial precedents cited on behalf of petitioner do not even exist and in some of the precedents, the quoted portions do not exist"
Sammaan Capital Ltd & Anr v. Mantri Infrastructure Pvt Ltd & Ors, Civil Revision Petition No. 49 of 2025; 2025 LiveLaw (Kar) 123
Who relied on it
the trial court
What was wrong
Two non-existent Supreme Court decisions: 'M/s. Jalan Trading Co. Pvt. Ltd. v. Millenium Telecom Ltd., Civil Appeal No. 5860/2010' and 'M/s. Kvalrner Cimentation India Ltd. v. M/s. Achil Builders Pvt. Ltd., Civil Appeal No. 6074/2018'.
What the court did
Trial court order set aside; Order VII Rule 10 application allowed and remitted; copy of the order placed before the Chief Justice 'for further action against the learned judge'
In the court's words
"on careful search, it is found that no such decision is rendered by the Hon'ble Apex Court"
Income Tax Appellate Tribunal, Bengaluru 'A' Bench — 30 December 2024
Matter
Buckeye Trust v. PCIT-2, Bangalore, ITA No. 1051/Bang/2024 (AY 2018-19)
Who relied on it
the tribunal's own order
What was wrong
Press: four non-existent rulings (three Supreme Court, one Madras High Court), names not published. Order text confirmed to contain misattributions e.g. 'CIT Vs Veenu Suresh Trust 221 ITR 649(Mad)' attributed to Bombay HC and 'CIT Vs Every stone 213 ITR 843 (Raj)'.
What the court did
Order recalled in toto on 7 Jan 2025 'on account of certain inadvertent errors'; rehearing fixed 19 Feb 2025; Karnataka HC W.P. 25280/2025 (M. Nagaprasanna J) restrained the judicial member in Aug 2025, matter reassigned by ITAT President, writ disposed as infructuous 18 Sep 2025. Stake: investments of INR 669,27,63,437.
In the court's words
"CIT Vs Every stone reported in 213 ITR 843 (Raj)"
Context: orders and hearings about AI where no invented citation was before the court
Supreme Court of India — 17 February 2026
Matter
Bench remarks during a PIL hearing on regulating political speeches ('Mercy v. Mankind')
Who relied on it
advocates generally
What was wrong
A citation 'Mercy v. Mankind' that never existed; real citations carrying quotations not found in the judgments; 'a series of such judgements' in Justice Dipankar Datta's court.
What the court did
Remarks only; no order, no costs
In the court's words
"We are alarmed to reflect now- some of the lawyers have started AI to draft. It is absolutely uncalled for."
Read it
primary document not located · a report of it · read through a report, not the order itself
Supreme Court of India — 5 December 2025
Matter
Kartikeya Rawal v. Union of India (PIL to regulate generative AI in the judiciary), W.P.(C) No. 1041/2025
Who relied on it
n/a - regulatory PIL, not an incident
What was wrong
n/a (petition warned of 'fabricated case laws through AI hallucination')
What the court did
Withdrawn with liberty to send suggestions to the Court's administrative side; Court said the issue is for the administrative side, not judicial orders
Read it
primary document not located · a report of it · read through a report, not the order itself
Manipur High Court — 23 May 2024
Matter
Md. Zakir Hussain v. State of Manipur & 2 Ors, WP(C) No. 70 of 2023
Who relied on it
the court itself
What was wrong
None reported. Context entry: no fabricated citation; compilations sometimes mislabel it.
What the court did
Petitioner (dismissed Village Defence Force member) reinstated
In the court's words
"this Court is compelled to do extra research through Google and ChatGPT 3.5 and collected some important information"
None. Context entry; Medianama: 'Not a hallucination case'.
What the court did
Bail decided on merits; ChatGPT answer reproduced for a 'broader picture'
Read it
primary document not located · a report of it · from a compilation or a search result only; not read at source
What verification means in practice
Find the judgment under the citation in a source that holds its text; read the passage relied on in that text; confirm the court, the parties and the date. A tool can do the first two and show the passage; it cannot do the reading. What Pundora's own check does, the words it uses, and what it does not catch are set out on how Pundora checks a citation.
Since the ruling
As of 3 October 2026 no guideline issued by the Bar Council of India under the Supreme Court's direction of 2 July 2026 was found on the pages that could be read. The Council's own website could not be read that day, so this is a statement that none was found, not that none exists. The Supreme Court's own matter arising from the Andhra Pradesh trial-court order (the special leave petition in Gummadi Usha Rani) was last traced to a hearing on 5 May 2026.
Questions advocates ask
Is it misconduct to cite an AI-generated case in an Indian court?
The Supreme Court held on 2 July 2026, in Pooja Ramesh Singh v. Jammu & Kashmir Bank Ltd, 2026 INSC 668, that citing such judgments without verification is misconduct on the part of an advocate, and directed the Bar Council of India to frame guiding principles.
Has any Indian court imposed costs for fake citations?
Yes. The entries above record what each court did, order by order: costs, warnings, references to the Bar Council, recall of orders, and the setting aside of decisions that relied on non-existent judgments.
How many such orders are there in India?
This register holds 21 that could be traced as of 3 October 2026. It is a record of what could be found, not a count of what exists.
How do I check that a citation is real?
Find the judgment under that citation in a source that holds the text, read the passage you rely on, and confirm the court, parties and date. See how Pundora checks a citation for what a tool can and cannot do.