Greenopolis Welfare Association (GWA) v. Narender Singh & Ors. (CM(M) 1909/2025)

Greenopolis Welfare Association (GWA) is described by ThePrint as a Gurugram-based group that presented itself as a homebuyers' association. It was a party to a civil suit in a Karkardooma court in Delhi in which Narender Singh and others, represented by a large team of counsel, were the plaintiffs. Between 18 and 22 September 2025 the trial court passed three orders, which the association challenged as arbitrary, hasty and procedurally irregular.¹²

The association challenged the orders in the Delhi High Court as a civil miscellaneous (main) petition, CM(M) 1909/2025, together with two applications. The matter came before Justice Girish Kathpalia on 25 September 2025, a week after the first of the impugned orders. Rakesh Tiku, Senior Advocate, appeared with other counsel for the petitioner, and N. Hariharan, Sanjoy Ghose and Ajay Sabharwal appeared for the respondents, among others.¹

The operative order is short. Paragraph 1 records that the petitioner "has assailed orders dated 18.09.2025, 20.09.2025 and 22.09.2025 of the learned trial court. However, after addressing partly, learned senior counsel for petitioner on instructions seeks permission to withdraw this petition." It continues: "All learned senior counsel and counsel appearing for respondents submit that they would take appropriate steps since some of the judicial precedents cited on behalf of petitioner do not even exist and in some of the precedents, the quoted portions do not exist." At the request of both sides, the court made clear that the submissions that day "were confined only to the impugned orders and nothing else". Paragraph 2 dismissed the petition and the accompanying applications as withdrawn.¹

The order does not name the affected authorities, state who prepared the petition, or mention AI. It records no costs, no notice for contempt and no direction to the Bar Council. Its restraint, and the agreed limit on what the court was deciding, mean that the order is a thin record of the problem.

ThePrint, reporting on 26 September 2025, supplied the detail. It said the respondents' lawyers had compared each cited position with the actual law in a table and found that the petition quoted a paragraph 73 of a Raj Narain v. Indira Gandhi judgment that, according to the report, has only 27 paragraphs, and that it presented as paragraph 21 of Dalip Singh v. State of U.P. (2010) a passage on litigants' conduct that actually appears in paragraph 2.² The respondents' counsel said the case laws were entirely non-existent and amounted to contempt, and Mr Ghose told ThePrint that the court would either take contempt action or prosecute for perjury. The respondents asked for permission to proceed against the lawyer responsible, but the article does not report a ruling on that request.²

The article's headline said the plea was "crafted by ChatGPT", and it said Justice Kathpalia observed orally that using AI in this manner was "impermissible". The basis stated for the AI attribution was the fabricated and inaccurate material and the respondents' lawyers' claims. The article reports no admission by the petitioner and no finding by the court that a chatbot was used, so the attribution to ChatGPT should be read as a press characterisation rather than a judicial finding.²

The case shows both forms of fabricated authority that AI hallucination produces: citations to cases that do not exist and quotations that do not appear in genuine judgments. The second is harder to catch because the case is real and its name is familiar. The same pattern, a real citation with an untraceable paragraph, later featured in the Supreme Court's analysis of the NCLT's reasoning in Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd.⁵

It also shows who detects the problem. In an adversarial system the check on a petitioner's authorities is often the opposing counsel. That worked here because the respondents' counsel checked the citations, and the Supreme Court has since observed that "Today's courts and tribunals implicitly trust lawyers when referring to precedents", adding that it would be impractical to ask a court to verify every cited judgment.⁵

The outcome, a withdrawal without recorded sanction, contrasts with the Supreme Court's later positions. On 2 July 2026 the Supreme Court declared that it is "a misconduct on the part of an advocate to cite such judgments without verification" and asked the Bar Council of India to frame disciplinary norms.⁵ In June 2026 the Bar Council of India was reported to have told Parliament that advocates who file AI-generated fake citations "cannot escape professional liability by blaming technology".⁶ The Supreme Court's draft Regulations for Use of Artificial Intelligence in Courts, 2026 would require parties to disclose AI-assisted filings and provide that a person whose submission is found fabricated or misleading by reason of its AI-generated character "shall not be entitled to rely upon the character of the AI output as a defence".⁸

The sources reviewed show few formal reactions to the order itself, in part because it records so little. SCC Online, in an April 2026 article on AI in trial courts, listed the episode among Indian hallucination incidents, describing it as a Delhi High Court dismissal as withdrawn of a petition containing fake case laws and non-existent quotes.⁴ Readers tracking the wider pattern should also see the Buckeye Trust tribunal order of December 2024 and the 2026 Supreme Court decisions covered elsewhere in this wiki.

A commentator in Bar & Bench's Viewpoint section wrote in September 2026 that generative AI can produce legal citations that look genuine but do not exist and that Indian courts are already affected; the piece urged independent verification of every citation before filing, though its author is a co-founder of a citation-verification company and the article carries a product pitch.⁹

As of 15 October 2026 the petition stands dismissed as withdrawn. The sources reviewed did not show any contempt proceeding, Bar Council complaint or other action against the lawyer or lawyers who prepared the petition. A separate revision petition by the same association (C.R.P. 287/2025), challenging a different trial court order of 26 September 2025 in Civil Suit No. 542/2025, was withdrawn before Justice Prateek Jalan on 11 December 2025, and that order does not mention AI or fabricated citations.³

The name "Greenopolis" should not be confused with an unrelated matter, Directorate of Enforcement v. Greenopolis Welfare Confederation, in which a Delhi High Court bench in September 2026 constituted a monitoring committee under former Chief Justice of India Sanjiv Khanna to oversee the claims of homebuyers in the stalled Greenopolis housing project in Gurugram. The article reporting it does not mention fake citations.⁷