Supreme Court Terms Use of AI-Generated Fake Judgments by Trial Court as Misconduct

In GUMMADI USHA RANI & ANR. v. SURE MALLIKARJUNA RAO & ANR, the Supreme Court has raised serious concerns over a trial court’s reliance on what were found to be AI-generated and non-existent judgments. The Court observed that such conduct may amount to misconduct and not merely a legal error.

A Bench of Justice Pamidighantam Sri Narasimha and Justice Alok Aradhe was hearing a special leave petition arising from a civil revision decided by the High Court of Andhra Pradesh. The matter, however, shifted focus from the dispute to the process adopted by the trial court.

The case relates to a suit for injunction filed by the respondents. During the proceedings, the trial court had appointed an Advocate Commissioner to inspect the disputed property and record its physical features. The defendants later objected to the Commissioner’s report.

By an order dated August 19, 2025, the trial court dismissed those objections. In doing so, it relied on four purported decisions of the Supreme Court. However, the defendants argued before the High Court that these cited judgments did not exist and were in fact fabricated.

The High Court examined the issue and found that the decisions referred to by the trial court appeared to be Artificial Intelligence-generated. Though it recorded a word of caution, it proceeded to decide the case on merits and ultimately upheld the trial court’s order.

Aggrieved by this outcome, the defendants approached the Supreme Court. The Bench made it clear that the matter raised “considerable institutional concern,” particularly regarding the integrity of the adjudicatory process.

The Court stated, “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.”

The Bench further observed that deploying AI-generated, non-existing or synthetic judgments directly impacts the credibility of judicial functioning. It indicated that the issue of accountability would be examined in detail.

Given the wider implications, the Court issued notice to the Attorney General for India, the Solicitor General of India and the Bar Council of India. Senior advocate Shyam Divan was appointed as amicus curiae to assist the Court.

This development comes amid growing judicial concern over the misuse of Artificial Intelligence in legal proceedings. The Supreme Court had recently flagged instances where lawyers cited AI-generated fake cases in pleadings.

The present case now places the spotlight on judicial accountability when such material finds its way into court orders. The outcome of this examination is likely to shape how AI tools are approached within the Indian judicial system.