The four forms a fabricated authority takes
A machine-produced authority fails in one of four ways, and each is caught by a different check: a citation that identifies no decision; a wrong citation attached to a decision that exists; a correct citation with a passage or paragraph that does not exist in it; and a decision that exists and is correctly cited but does not hold what it is cited for. Only the last two survive a check that the case exists.
When this decides something for you
A professional who has learned that machines invent cases checks that each case exists, finds that it does, and files. That check catches only half of what the machine does. The Supreme Court of India, verifying the citations in two orders itself, found four distinct kinds of failure, and a verification routine built around "does the case exist?" would have passed two of them. This page lists the four so that the routine covers all of them.
The question
In what ways does a machine-supplied authority turn out not to be one, and which check catches each?
The premise
A machine that generates text produces the form of a citation because the form is a pattern it has seen many times. The form carries no guarantee about the decision, the passage or the holding, because the machine does not consult any of them when it produces the form. So the failure can sit at any of four levels, and the form looks the same at each.
How it works
The four forms, as the Supreme Court found them.
A citation that identifies no decision. The case name, volume and page do not correspond to any reported case. In Pooja Ramesh Singh the Court found three of six citations relied on by the tribunal to be of this kind, including one at (2019) 16 SCC 528 and one at (2022) 7 SCC 464 that identify nothing. Caught by the existence check: open the volume, or the court's record, and the case is not there.
A wrong citation attached to a decision that exists. The reference exists but belongs to a different case. In the same judgment the Court found that 2020 SCC OnLine SC 341, cited for a case between a bank and an infrastructure company, is in fact the citation of M. Subramaniam v. S. Janaki. Caught by the existence check, but only if the checker compares the case name to the case found at the reference, not merely that something is found there.
A correct citation with a passage that does not exist in it. The decision exists, the reference is right, and the quoted paragraph is not in it. The Court found two such in Pooja Ramesh Singh, at (2015) 2 SCC 1 and (2018) 16 SCC 228: "correct citation but non-existent paragraph". Not caught by the existence check. Caught only by reading the decision at the paragraph relied on and comparing it with the quotation.
A decision that exists, is correctly cited, and does not hold what it is cited for. In Gadiya the Court found that some of the cases relied on by the adjudicating officer "which do exist, do not lay down the ratio deduced therefrom and it appears to be a hallucination of AI". Not caught by the existence check, nor by finding the quoted words, if the machine has attributed a holding rather than a quotation. Caught only by reading the decision for what it decided, on which facts, and comparing that with the proposition it is cited for.
The four forms are ordered by the depth of reading each requires: none, the name, the paragraph, the holding. A verification routine is adequate only if it reaches the fourth level for every authority relied on, which is why the routine is a ledger row with the proposition carried, the points to confirm and the direction of the holding, not a search for the case.
One case
Gummadi Usha Rani v. Sure Mallikarjuna Rao, SLP(C) No.7575 of 2026, Supreme Court of India, order dated 27 February 2026. The trial court relied on four decisions cited as reported Supreme Court cases with volume and page; the defendants contended that they did not exist; the High Court found they were generated by artificial intelligence. All four were of the first form. The High Court, having found this, affirmed the order on its merits, which is the response the first form invites: treat the fabrication as a citation error and look past it. The Supreme Court's response was different: a decision based on such material "is not an error in the decision making. It would be a misconduct."
The rule
Check that the case exists, that the name matches the reference, that the passage is in it, and that it holds what it is cited for. A check that stops early passes the forms the machine produces most easily.
Not to be confused with
These are forms of fabricated authority, not causes. Why a model produces them is a question about how such systems generate text, answered elsewhere in this library. The professional's routine does not depend on the answer; it depends on reaching the fourth level of reading for every authority relied on.
Provenance and method.
Where this was published
- Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd
- 2026 INSC 668
- paras 14 to 16
- Vijay Ghanshyam Gadiya v. Union of India
- 2026 INSC 947
- para 4
- Gummadi Usha Rani v. Sure Mallikarjuna Rao
- SLP(C) No.7575 of 2026
- order of 27 February 2026
- paras 2 to 4
Changelog
- 2026-09-25, version 1. First published.