Fake AI Citations in Indian Courts: Cases, Costs and Lessons (2026)

Fake AI citations in Indian courts have moved from embarrassment to misconduct. Since 2024, petitions have been withdrawn in the Delhi High Court, costs of ₹50,000 imposed by the Bombay High Court, a ₹27.91 crore tax assessment quashed, and on 2 July 2026 the Supreme Court set aside NCLT and NCLAT orders built on six non-existent or misquoted decisions. In Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd. the Court declared “zero tolerance” and said an advocate who cites such judgments without verifying them commits misconduct.

Fake AI citations in Indian courts: the reported cases

Most fake AI citations in Indian courts reach the news through LiveLaw, Bar and Bench and the SCC Online blog. Read the original order before citing any of these.

1. Delhi High Court, August 2023, Christian Louboutin SAS v. The Shoe Boutique: the court declined to rely on ChatGPT responses and said such tools cannot be the basis for deciding legal or factual issues.
2. ITAT Bengaluru, Buckeye Trust v. PCIT: an order of December 2024 was recalled within about a week after it was found to refer to decisions that could not be traced.
3. Delhi High Court, September 2025, Greenopolis Welfare Association v. Narender Singh: a petition cited paragraph 73 of Raj Narain v. Indira Nehru Gandhi, (1972) 3 SCC 850, a judgment with only 27 paragraphs. The petition was withdrawn.
4. Bombay High Court, October 2025, KMG Wires Pvt. Ltd. v. National Faceless Assessment Centre: an addition of about ₹27.91 crore was quashed because the officer relied on non-existent decisions.
5. Bombay High Court, 7 January 2026: ₹50,000 costs on a litigant in a rent matter whose written submissions appeared AI-prepared. In March 2026 the Supreme Court expunged the remarks as an indulgence, while calling fake AI judgments a worldwide menace.
6. Supreme Court, 27 February 2026, Gummadi Usha Rani v. Sure Mallikarjuna Rao: a trial court had relied on non-existent decisions; the Court called this misconduct, not a mere error.

What Pooja Ramesh Singh v. J&K Bank decided

In insolvency proceedings, the NCLT admitted an application relying on six decisions, and the NCLAT repeated them. Three citations did not exist, two pointed to paragraphs that do not exist, and one was a wrong citation to a real case. The bank said they were not cited at the bar; the NCLT appears to have found them in its own research.

• Both orders were set aside and the application was restored to the NCLT for a fresh decision on merits.
• The Court said a decision based on fake material is no decision at all.
• For a judge, relying on such material is a serious lapse. For an advocate, citing it without verifying is misconduct.
• The BCI was asked to frame guiding principles and disciplinary consequences.

Why AI tools invent judgments

A large language model does not look cases up. It predicts likely text. Indian legal writing is full of patterns such as “In X v. Y, (year) volume SCC page, the Supreme Court held”, so the model can produce a perfect-looking citation for a case that never existed. Warning signs:

• a quotation that supports your exact point in your exact words;
• a paragraph pinpoint in a judgment you know to be short;
• old IPC or CrPC sections presented as current law after 1 July 2024.

Asking the chatbot “are these cases real?” proves nothing. That is how fake AI citations in Indian courts keep happening.

Found a fake citation? What to do, in order

1. In your own draft, before filing: remove it, then check every other authority from the same source, because errors cluster.
2. In your own filing, after filing: confirm the problem, tell your senior and the client, and bring it to the court’s notice at the earliest opportunity in the manner the court’s practice allows.
3. In the other side’s filing: search by party name and by citation in more than one source, then point it out courteously with what you searched.
4. In an order against your client: document your searches and raise the ground in review, appeal or revision within limitation. Pooja Ramesh Singh shows the Supreme Court will set such orders aside.

Frequently asked questions

What happens if a lawyer cites a fake AI case in an Indian court?

Courts can refuse to consider the filing, impose costs, or set aside any order resting on it. Since Pooja Ramesh Singh (2 July 2026), citing AI-generated precedent without verification is treated as misconduct by the advocate, which can lead to action under s.35 of the Advocates Act, 1961.

Have costs been imposed for fake AI citations in Indian courts?

Yes. The Bombay High Court imposed ₹50,000 costs on a litigant on 7 January 2026 where written submissions cited an untraceable case and appeared AI-prepared. The Supreme Court later expunged the remarks as an indulgence, without deciding whether the case had been cited.

Can an order based on fake AI citations be challenged?

Yes. In Pooja Ramesh Singh the Supreme Court set aside NCLT and NCLAT orders that relied on six non-existent or misquoted decisions. Document your searches carefully and use the proper remedy within limitation.

Did the Supreme Court ban AI in courts?

No. The Court said legitimate use of AI is not barred; what is barred is citing AI-generated material as precedent without verification. Its June 2026 draft regulations also allow assistive uses such as research and translation.

Quick quiz

Learn the full verification method in the AI for Lawyers and Law Students certificate course, ₹499.

Sources

• Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd., Supreme Court, 2 July 2026, 2026 INSC 668
• Gummadi Usha Rani v. Sure Mallikarjuna Rao, Supreme Court, order of 27 February 2026
• Greenopolis Welfare Association v. Narender Singh, Delhi High Court, September 2025; Christian Louboutin SAS v. The Shoe Boutique, Delhi High Court, August 2023
• KMG Wires Pvt. Ltd. v. National Faceless Assessment Centre, Bombay High Court, October 2025; Bombay High Court order of 7 January 2026 (rent matter)
• Buckeye Trust v. PCIT, ITAT Bengaluru (order of December 2024, recalled)
• Advocates Act, 1961, s.35; Bar Council of India Rules, Part VI, Chapter II

This page is for education and general information, not legal advice for a specific case. Law as on 31 October 2026.