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CDJ 2026 SC 350 print Preview print Next print
Court : Supreme Court of India
Case No : Petition(s) for Special Leave to Appeal (C) No(s). 7575 of 2026
Judges: THE HONOURABLE MR. JUSTICE PAMIDIGHANTAM SRI NARASIMHA & THE HONOURABLE MR. JUSTICE ALOK ARADHE
Parties : Gummadi Usha Rani & Another Versus Sure Mallikarjuna Rao & Another
Appearing Advocates : For the Petitioners: ----- For the Respondents: ----
Date of Judgment : 27-02-2026
Head Note :-
Subject
Summary :-
1. Statutes / Acts / Rules / Orders / Regulations Mentioned:
- None

2. Catch Words:
- injunction
- civil revision petition
- Artificial Intelligence (AI) generated judgments
- misconduct
- accountability
- notice

3. Summary:
The petitioners, defendants in an injunction suit, challenged the Trial Court’s acceptance of an Advocate Commissioner’s report, alleging that the judgments cited by the Trial Court were fabricated and AI‑generated. The High Court dismissed the civil revision petition, affirming the Trial Court’s order, but noted the artificial nature of the cited judgments and cautioned the parties. The matter is now before the Supreme Court, which has issued notices and directed that the Trial Court not rely on the Advocate Commissioner’s report pending the outcome of the Special Leave Petition. The Court also seeks input from the Attorney General, Solicitor General, and Bar Council of India, and has appointed senior counsel to assist. The Court emphasizes that reliance on non‑existent judgments constitutes misconduct, not merely an error.

4. Conclusion:
Petition Dismissed
Judgment :-

1. This 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.

2. The petitioners are the defendants in a suit filed by the respondents for injunction. Pending disposal of the suit, the Trial Court appointed an Advocate Commissioner to note the physical features of the property. The petitioners challenged the report of the Advocate Commissioner by raising certain objections. The Trial Court, by its order dated 19.08.2025 dismissed the objection and in the process, relied on certain decisions being; i) Subramani v. M. Natarajan (2013) 14 SCC 95, ii) Chidambaram Pillai v. SAL Ramasamy (1071) 2 SCC 68, iii) Lakshmi Devi v. K. Prabha (2006) 5 SCC 551 and iv) Gajanan v. Ramdas (2015) 6 SCC 223.

3. The petitioners challenged the orders passed by the Trial Court, inter alia, contending that the judgments referred to and relied on are non-existent and fake orders.

4. The High Court considered the objection and realized that the judgments are Artificial Intelligence (AI) generated and after recording a word of caution proceeded to decide the case on merits and dismissed the civil revision petition affirming the decision of the Trial Court. Thus, the petitioner is before us.

5. Issue notice, returnable on 10.03.2026.

6. Pending disposal of the Special Leave Petition, we direct that the Trial Court shall not proceed on the basis of the Advocate Commissioner's Report.

7. 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.

8. Issue notice to the Ld. Attorney General, Ld. Solicitor General and the Bar Council of India.

9. We appoint Mr. Shyam Divan, learned senior counsel, to assist the Court. He may nominate an Advocate on Record for his assistance.

 
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