Gummadi Usha Rani v. Sure Mallikarjuna Rao (Supreme Court of India, 27 February 2026)
Case note. SLP(C) No.7575 of 2026. A trial court's order relied on four Supreme Court decisions that do not exist; the High Court found them AI-generated and affirmed on the merits; the Supreme Court issued notice, stayed reliance on the report, declared that a decision based on non-existent judgments "is not an error in the decision making. It would be a misconduct", issued notice to the Attorney General, the Solicitor General and the Bar Council of India, and appointed a senior counsel to assist.
The proceeding
Petition for Special Leave to Appeal (Civil) No.7575 of 2026, arising from the judgment and order of the High Court of Andhra Pradesh at Amravati dated 21 January 2026 in CRP No.2487 of 2025. Heard for admission on 27 February 2026 by Narasimha and Aradhe JJ. Counsel for the petitioners: Ms Sindoora Vnl, AOR, with Ms Thithiksha Padmam. No appearance recorded for the respondents at that stage.
What happened below
The petitioners are defendants in a suit for injunction. Pending the suit, the trial court appointed an Advocate Commissioner to note the physical features of the property. The petitioners objected to the Commissioner's report. By order dated 19 August 2025 the trial court dismissed the objections and, in doing so, relied on four decisions: Subramani v. M. Natarajan (2013) 14 SCC 95; Chidambaram Pillai v. SAL Ramasamy, cited as (1071) 2 SCC 68; Lakshmi Devi v. K. Prabha (2006) 5 SCC 551; and Gajanan v. Ramdas (2015) 6 SCC 223 (paragraph 2).
The petitioners challenged the order contending that the judgments referred to and relied on "are non-existent and fake orders" (paragraph 3). The High Court considered the objection, "realized that the judgments are Artificial Intelligence (AI) generated", recorded a word of caution, and proceeded to decide the revision on its merits, dismissing it and affirming the trial court (paragraph 4).
What the Supreme Court ordered
The Court opened by saying that the case "assumes considerable institutional concern, not because of the decision that was taken on the merits of the case, but about the process of adjudication and determination" (paragraph 1). It issued notice returnable on 10 March 2026 (paragraph 5) and directed that, pending disposal, the trial court "shall not proceed on the basis of the Advocate Commissioner's Report" (paragraph 6).
Paragraph 7 is the operative statement: "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 integrity of adjudicatory process. 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 a misconduct and legal consequence shall follow. It is compelling that we examine this issue in more detail."
Notice was issued to the Attorney General, the Solicitor General and the Bar Council of India (paragraph 8). Mr Shyam Divan, senior counsel, was appointed to assist the Court, with liberty to nominate an Advocate on Record (paragraph 9).
Why it matters
Three features fix the case's place in the record. The fabrication was the court's own, not an advocate's: the trial judge relied on the four decisions in the order. The intermediate court, having found the fabrication, treated it as a defect to be noted and looked past, and decided the merits. The Supreme Court refused that framing in terms: the defect is in the process, it is misconduct rather than error, and it carries consequences for the person holding the office. A further order of 5 May 2026 in the same matter is recorded in the author's ledger and is not summarised here until read.
The four forms
All four citations were of the first form on the library's page on fabricated authority: references that identify no decision. The year "1071" in the second is the machine's, reproduced in the Supreme Court's own order as the trial court gave it.
Provenance and method.
Where this was published
- Gummadi Usha Rani & Anr v. Sure Mallikarjuna Rao & Anr
- SLP(C) No.7575 of 2026
- Supreme Court of India
- order dated 27 February 2026 (Narasimha and Aradhe JJ)
- Item No.22
- Court No.6 (archived copy A2
- digitally signed 28 February 2026
- read 25 September 2026)
Changelog
- 2026-09-25, version 1. First published.