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 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.
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 (v1.0.2, 13 September 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.
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.
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.
Deepak Bahry v. Heart and Soul Entertainment
In an eviction dispute, a litigant's submissions cited a judgment the Court could not trace in any database. The Court noted tell-tale marks of machine-generated output, including formatting artefacts and repetitive phrasing, imposed costs of fifty thousand rupees, and recorded the failure of verification as a professional conduct failure.
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.
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.
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.
Buckeye Trust v. PCIT
In a dispute involving several hundred crores, the Tribunal ruled for the revenue on the strength of three fabricated Supreme Court citations and one fabricated Madras High Court citation, reportedly sourced by the department's representative through a chatbot and copied into the order without verification. The Tribunal recalled the order. The entry marks the earliest widely documented Indian incident of fabricated authority entering a decisional record.
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.
- v1.0.2, 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.