The Register of AI-Fabricated Authority in Indian Proceedings.
A maintained, structured record of documented incidents in which artificial intelligence produced fabricated, misattributed, or misrepresented authority, or unsupervised machine-drafted content, in Indian judicial and quasi-judicial proceedings. Each entry carries a stable accession number, a defect classification, the recorded consequence, and its sources. The Register is updated as incidents are documented and is offered as a citable reference for practitioners, courts, researchers, and journalists.
Scope and method.
Scope. The Register records incidents in Indian proceedings, before courts, tribunals, and quasi-judicial authorities, in which content generated by artificial intelligence and carrying defective legal authority, or bearing the marks of unsupervised machine drafting, entered the record: in a party's pleading or submission, in a notice or quasi-judicial order, or in a judicial order itself. Institutional and regulatory responses are recorded separately in Part B.
Taxonomy. Entries are classified by defect type. The three citation defects carry different detection burdens and different culpability, and the Register keeps them distinct.
- Fabrication
- The cited authority does not exist. No judgment by that name, in that reporter, at that citation, was ever delivered.
- Fabricated content in genuine authority
- The authority exists, but the quoted passages, paragraphs, or propositions attributed to it were invented.
- Misattribution
- The cited object exists, but the citation, title, or reference points to the wrong case or the wrong source.
- Misrepresentation
- The citation is accurate, but the authority does not support the proposition for which it is advanced.
- Unsupervised machine drafting
- Content bearing structural marks of machine generation, filed without the supervision, factual grounding, or comprehension that professional responsibility requires.
Introduced by. From version 1.2, each entry records who placed the defective material on the record, as the order or judgment itself shows: counsel; party in person; judge; tribunal or quasi-judicial body (a tribunal or appellate authority deciding between parties); or executive officer (a departmental officer issuing a notice, an assessment, or an order-in-original). Where the record does not show who introduced the material, the entry says so. Where the court's finding is provisional, or the defect is established but its source in artificial intelligence is not determined, the entry states the level of the finding.
Sources and verification. Entries are compiled from orders and judgments where citations are available, and from reporting of record where they are not. Neutral citations and case numbers are stated as reported and are progressively verified against primary sources; the Register's maintenance protocol treats every entry as subject to the same verification discipline it documents the absence of. Corrections, additions, and primary documents are invited at shivam@advshivamshukla.in.
Shivam Shukla, The Register of AI-Fabricated Authority in Indian Proceedings, advshivamshukla.in/register (v1.2, 4 October 2026). Individual entries may be cited by accession number, for example Register entry R-09. The Register is published under a CC BY 4.0 licence: reuse with attribution is welcome.
The incidents.
Vijay Ghanshyam Gadiya v. Union of India
An Additional Commissioner of Customs, Surat, by an Order-in-Original of 8 October 2025, imposed a penalty of Rs 425.28 crore on a diamond trader under Section 114 of the Customs Act 1962, resting the order on case law the Supreme Court verified to be either non-existent, carrying fake citations, or genuine but not laying down the ratio deduced from it, material the Court found to be an apparent hallucination of AI. The Gujarat High Court had affirmed the order in January 2026, and the defect travelled undetected to the Supreme Court. Applying the zero-tolerance standard of entry R-09, the Court held that assistance can never be substituted for adjudication, observed that AI may serve as training wheels but that entrusting it with the pilot's seat would be both imprudent and dangerous, set aside the High Court's order and the Order-in-Original, remanded the proceedings for fresh adjudication by a different officer of the same rank, and left action against the author of the order to his appointing authority. The entry records the second migration of the defect into the quasi-judicial state after entry R-04, the first application of the R-09 standard to executive adjudication, and a failure of the appellate checkpoint on the way.
Faiz Enterprise v. State Tax Officer
A probationary State Tax Officer at Surat cancelled a trader's GST registration by an order that relied on three authorities: one does not exist, and the other two carry citations and ratios that do not match the decisions named. The cancellation survived an application for revocation and a departmental appeal. On 13 August 2026 the High Court observed that the order appeared to rest exclusively on AI-generated case law and required the department to answer. Before the next hearing the Additional Commissioner of State Tax issued instructions to all adjudicating and quasi-judicial authorities in the department: every authority identified through AI must be verified from primary official sources; where a tool paraphrases a ratio, the original paragraph must be located and reproduced verbatim; and an order resting on unverified AI content amounts to misconduct. At that hearing the officer tendered an unconditional apology on affidavit, admitting that he had used artificial intelligence to draft the order and to cite the judgments. The Court quashed the show cause notice, the cancellation, the rejection of revocation, and the appellate order, directed fresh proceedings ending in a reasoned order, and declared that any violation of the instructions would amount to contempt of the Court. The entry records an author's own admission of AI use, made on affidavit, and a court converting a department's verification protocol into a direction enforceable in contempt.
Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd.
In the appeal arising from the Essel Infraprojects insolvency, the Supreme Court found that of six judgments relied upon by the National Company Law Tribunal, three did not exist and three were genuine citations carrying invented paragraphs or an incorrect title. No counsel had cited them; the Tribunal sourced the material through its own research, and the defects passed unnoticed through the Appellate Tribunal. The Court set aside both orders, held that a decision resting on such material is no decision in the eyes of the law, prescribed zero tolerance for producing, citing, or using AI-generated precedents without verification, characterised the conduct as misconduct for an advocate and a serious lapse for a judge, directed the Bar Council of India to constitute a committee, prescribe guiding principles, and specify disciplinary consequences, and likened hallucinated case law to the release of methyl isocyanate in the province of law and justice. The standard was applied to executive adjudication two months later in entry R-10.
Principal, Woodland House School v. Shakeel Ahmad Malik
In execution proceedings arising from a salary dispute, an order of the 4th Additional Munsiff, Srinagar, dated 15 October 2025, rested principally on two judgments. On an independent verification undertaken by the High Court, one could not be traced under the title or the citation given and did not appear to exist in the form cited; the other bore a similar title to a genuine decision but a citation that did not correspond to it. The High Court held that the defect did not by itself warrant interference, upheld the order on its merits, and dismissed the petition with costs of twenty-five thousand rupees for abuse of process. In a postscript it held that responsibility for the correctness of a judicial order rests solely on the judge who authors it, cautioned against paraphrasing a ratio instead of reproducing it, and directed all judicial officers in the Union Territory to verify independently any citation, extract, or proposition obtained through artificial intelligence tools, to give a complete and accurate citation for every precedent, to reproduce verbatim the extract on which a finding rests, and to cross-verify citations taken from unofficial or secondary sources; the judgment was circulated to all judicial officers through the Registrars Judicial. The entry records a court that verified, found the defect, and let the order stand, the tolerance that entry R-09 displaced four weeks later.
SNV Aviation Pvt. Ltd. v. ABS Tour and Travels
A District Judge (Commercial) at Saket decreed a suit against the operator of Akasa Air for Rs 1,08,80,000 by a judgment of 24 February 2026. On appeal, the airline placed before the High Court a chart of Supreme Court decisions to which, it alleged, the judgment attributed propositions those decisions do not contain, and contended that the judgment, including the passages distinguishing the airline's authorities, had been drafted with artificial intelligence software. The Division Bench recorded that the manner of drafting prima facie gave an impression that some AI software may have been used, held that this could not be conclusively said until further examination of whether such software had been used and whether the judgment had been properly reviewed, observed that the attribution of non-existent propositions to judgments is a matter of concern, stayed the decree subject to a deposit of twenty lakh rupees, and requisitioned the trial court record. The entry is recorded at the level of finding the Court has reached and will be revised on final determination.
Gummadi Usha Rani v. Sure Mallikarjuna Rao
A trial court at Vijayawada, by an order of August 2025 dismissing objections to an Advocate Commissioner's report, relied on four Supreme Court judgments that do not exist in any law reporter. The Andhra Pradesh High Court accepted that the citations were AI-generated but declined to set the order aside, reasoning that non-existent citations do not vitiate an order where the legal principle applied is correct, and recorded a word of caution. On further challenge, the Supreme Court took cognizance, declared that a decision based on non-existent and fake judgments is not an error in decision-making but misconduct with legal consequences, stayed reliance on the disputed report, issued notice to the Attorney General, the Solicitor General, and the Bar Council of India, and appointed Mr. Shyam Divan, Senior Advocate, as amicus curiae. The July 2026 ruling in entry R-09 subsequently displaced the High Court's tolerance with a categorical standard.
The "Mercy v. Mankind" observations
While hearing a public interest litigation, a bench headed by the Chief Justice of India flagged the growing use of artificial intelligence to draft petitions. Justice B. V. Nagarathna recorded that she had encountered a non-existent case titled Mercy v. Mankind cited before the Court, and the Chief Justice observed that a series of such judgments had been cited in another judge's court. The observations placed on record that fabricated authority had reached the Supreme Court's own filings.
Gayathri v. Guru Reddy Raju S. N.
In a partition suit pending for fourteen years, the judgment of an Additional City Civil and Sessions Judge, as digitally signed and published, carries the text of an exchange with a generative AI system: the system's offers to “tighten the language” and to “prepare a separate decree sheet”, the judge's instructions to it, including a correction rejecting the system's first reading of a will as creating a life interest, and both the rejected and the corrected analyses, the abandoned one left in the text. The findings on the issues are left blank, the reasoning on the principal issues is replaced by a line of x-characters, the concluding paragraph states that the suit deserves to be dismissed while the operative order partly decrees it, and the judgment records three different dates of pronouncement. No fabricated citation is recorded. The entry documents the unsupervised-machine-drafting defect inside a judgment: the drafting process itself, signed into the record.
Deepak Bahry v. Heart and Soul Entertainment
In an eviction dispute, written submissions filed by the respondent company through its director, appearing in person, cited a judgment that neither the Court nor its law clerks could find. The Court noted tell-tale marks of machine-generated output, including formatting artefacts and repetitive submissions, held that a party or advocate using such tools must verify that the material exists, warned that an advocate found doing so may be referred to the Bar Council, and imposed costs of fifty thousand rupees for the respondent's conduct of the litigation, of which the untraceable citation formed part.
Blue Star Aluminium v. Federal Bank
The Court confronted multiple writ petitions that carried formal legal structure but omitted material facts, drafted so mechanically that the advocates on record could not answer the Court's questions about their own pleadings. The episode records the drafting-side failure mode: machine-assembled pleadings filed without the supervision or comprehension that professional responsibility requires.
M/s J. M. Jain v. Union of India
A show cause notice issued by the Directorate General of GST Intelligence, Delhi Zonal Unit, proposing demands on the strength of material from an income-tax search, cited three judgments on the evidentiary value of statements recorded under Section 132(4) of the Income-tax Act. The Court sent for the physical volumes from its library. One judgment was correctly cited. A second, Surjeet Singh Chhabda v. Union of India, was found not to exist at the citation given, which belongs to a different case; the department's counsel maintained that only the citation was wrong. The third carried a title that did not match the judgment at its citation. Observing that a department citing material produced through artificial intelligence runs a clear possibility of citing fake judgments, the Court held that the GST and income-tax departments must take full responsibility for citations generated with such tools and that all judgments must be verified before a show cause notice is issued or an assessment finalised. The challenge to the notice was held premature and the petitioner was directed to reply to it; the notice was not quashed. The entry records a court verifying by physical volume, and a citation defect that did not, at the notice stage, defeat the proceeding.
KMG Wires Pvt. Ltd. v. National Faceless Assessment Centre
In faceless assessment proceedings, the assessing officer justified a multi-crore addition to the assessee's income by citing three decisions that do not exist. The Court quashed the assessment order as a breach of natural justice and warned that quasi-judicial authorities cannot blindly rely on the results of artificial intelligence tools. The entry records the migration of the defect into the quasi-judicial state: the algorithmic assessment infrastructure producing fabricated authority against the citizen.
Greenopolis Welfare Association v. Narender Singh
A petition in a flat-possession dispute quoted paragraphs 73 and 74 of the Raj Narain judgment. The judgment runs to twenty-seven paragraphs. Opposing counsel exposed the citations as fabricated and the petition was withdrawn. The entry is the cleanest documented Indian example of fabricated content attributed to a genuine authority: the case exists, the passages do not. The High Court's order records that some precedents cited for the petitioner did not exist and that, in some, the quoted portions did not exist; the identification of the Raj Narain paragraphs and the attribution to artificial intelligence rest on reporting of record.
Inquiry against a City Civil Court judge, Bengaluru
A judge of the City Civil Court rejected a return-of-plaint application in a commercial dispute by relying on two Supreme Court decisions that were never delivered. Senior counsel confirmed that neither side had cited them. The High Court directed an inquiry and action against the judicial officer, one of the earliest instances in which a High Court moved against a judge, rather than an advocate, over hallucinated citations. The impugned order is dated 25 November 2024, which makes it the earliest dated instance in this Register, although it came to light only when the revision was heard in 2025. The High Court's order does not itself attribute the citations to artificial intelligence.
Buckeye Trust v. PCIT
In a dispute involving several hundred crores, the Tribunal ruled for the revenue on the strength of three Supreme Court citations and one Madras High Court citation reported to be fabricated. Early reporting attributed them to the department's representative. The Tribunal recalled the order on 7 January 2025. The Karnataka High Court later recorded that the order prima facie indicated that it was driven by artificial intelligence, an indication vindicated by the recall; restrained the Judicial Member who authored it from rehearing the appeal; and disposed of the writ once the appeal was assigned to a different bench, which decided it afresh in February 2026. The entry marks the earliest widely documented Indian incident of fabricated authority entering a decisional record; the earlier-dated order in entry R-02 came to light later.
The institutional response.
The doctrinal analysis of this record, and the practitioner standard built in response to it, are set out in the essay From Misconduct to Method and on the Standard page.
- v1.2, 4 October 2026. Five entries added, each verified against the judgment or order text on the date of entry: R-11 (M/s J. M. Jain v. Union of India, Delhi High Court), R-12 (Gayathri v. Guru Reddy Raju S. N., City Civil Court, Bengaluru), R-13 (SNV Aviation v. ABS Tour and Travels, Delhi High Court, recorded at the prima facie level of finding), R-14 (Principal, Woodland House School v. Shakeel Ahmad Malik, High Court of Jammu & Kashmir and Ladakh), and R-15 (Faiz Enterprise v. State Tax Officer, Gujarat High Court). Accession numbers follow the order of entry; Part A remains arranged by date of the recorded decision, so new entries sit among the earlier ones. A new field, Introduced by, added to every entry, with a Finding field where the court's finding is provisional or the source in AI is not determined; the method section explains both. Corrections on verification against primary records: R-01 now records the Karnataka High Court's order in Writ Petition No. 25280 of 2025, which found the Tribunal's order prima facie AI-driven and restrained its author from rehearing, in place of reporting that attributed the citations to the department's representative; R-02 records the case title, the CRP number, the date of the impugned order (25 November 2024), and that the High Court's order does not itself attribute the citations to AI; R-03 records the case number and that the Raj Narain paragraphs and the AI attribution rest on reporting, not on the order; R-04 records the writ petition number, neutral citation, Bench, and the seven-day notice direction; R-06 records that the submissions were filed through the respondent company's director in person, that the Court and its law clerks could not find the cited judgment, the Bar Council warning, and that the costs rest on the respondent's conduct of the litigation as a whole. Scope extended in terms to notices. Two institutional responses added to Part B. Incident count: fifteen.
- v1.1, 17 September 2026. Entry R-10 added: Vijay Ghanshyam Gadiya v. Union of India, 2026 INSC 947, the Supreme Court's application of the R-09 zero-tolerance standard to executive adjudication, verified against the judgment text on the date of entry. A cross-reference to R-10 added to entry R-09. Incident count: ten. The SCC OnLine reporter number the Gadiya judgment records for entry R-09 is noted but not adopted pending independent confirmation, in keeping with the v1.0.2 discipline.
- v1.0.2, 13 September 2026. Entry R-08 (Gummadi): the unverified reported citation "2026 SCC OnLine SC 341" removed; the entry now rests on the SLP number, the order date, and the Supreme Court primary PDF, which are verified. The removed reporter number could not be independently confirmed and coincided with a citation flagged as fabricated in entry R-09, so it is withdrawn out of the same verification discipline the Register documents.
- v1.0.1, 22 July 2026. Verification pass against primary records: Supreme Court PDF added as primary source for entries R-08 and R-09; R-09 citation line corrected to "judgment dated"; verified reported citation 2026 SCC OnLine Bom 209 added to entry R-06.
- v1.0, 22 July 2026. Initial publication: nine incidents (R-01 to R-09), seven institutional responses, taxonomy, and methodology.
The Register is reviewed against new orders and reporting monthly. Documented incidents not yet recorded here may be submitted with sources to shivam@advshivamshukla.in.
The Register, maintained.
Updates to the Register, Field Notes, and essays on AI, law, and professional responsibility, by email. Occasional, signal only.