Gummadi Usha Rani & Anr. v. Sure Mallikarjuna Rao & Anr. (SLP (C) No. 7575/2026)

The underlying dispute is an ordinary civil suit for injunction in Andhra Pradesh. Pending trial, the trial court appointed an Advocate Commissioner to note the physical features of the property. The defendants, Gummadi Usha Rani and another, objected to the Commissioner's report, and by an order of 19 August 2025 the trial court dismissed the objections. In doing so it relied on four decisions, which the Supreme Court's order lists as Subramani v. M. Natarajan (2013) 14 SCC 95, Chidambaram Pillai v. SAL Ramasamy (1071) 2 SCC 68, Lakshmi Devi v. K. Prabha (2006) 5 SCC 551 and Gajanan v. Ramdas (2015) 6 SCC 223.¹²

The defendants argued that the judgments were non-existent and fake. They took the point to the Andhra Pradesh High Court in a civil revision petition (CRP No. 2487/2025). According to the Supreme Court's order, the High Court "considered the objection and realized that the judgments are Artificial Intelligence (AI) generated", recorded "a word of caution", and then decided the revision on its merits, affirming the trial court. The judgment of 21 January 2026 left the petitioners with a decision they said rested on invented authority, and they went to the Supreme Court.¹

The Bench of Justices P.S. Narasimha and Alok Aradhe heard the special leave petition at the admission stage and began by framing it as an institutional matter: the 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".¹

The Court issued notice returnable on 10 March 2026 and directed that, pending disposal, the trial court "shall not proceed on the basis of the Advocate Commissioner's Report". It then stated: "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."¹ It issued notice to the Attorney General, the Solicitor General and the Bar Council of India, and appointed Senior Advocate Shyam Divan as amicus curiae, with liberty to nominate an Advocate-on-Record. Advocates Sindoora VNL and Thithiksha Padmam appeared for the petitioners.¹²

The next substantive hearing, reported by Bar & Bench, produced no written direction but showed the Bench's thinking. The Court said orally that it wanted the Bar Council of India "to constitute a committee of experts, including outside experts, and file a report", while stating that it was not passing an order. The Attorney General, R. Venkataramani, said he had suggestions but would first engage with the Ministry of Electronics and Information Technology. The Bench replied that the Supreme Court's AI Committee was "almost at the verge of finalising the draft regulations", which would then be thrown open for consultation.³

The Bench said that its concern went beyond regulation to the obligation of the Bar in placing synthetic or non-existent orders before courts and asked where responsibility lies when a judge's own research turns up a non-existent judgment. Mr Divan told the Bench that the Supreme Court's Centre for Research and Planning had prepared a white paper on AI in the judiciary containing recommendations and guidelines that could be a starting point. The Bench also remarked that the absence of sovereign large language models, and reliance on open-source algorithms, made "hallucinations invariable", and indicated the need for a sovereign database and an India-based AI model.³ The written record for the day says only that the matter was listed on 26 May 2026.⁴

On 26 May 2026, at the oral request of the petitioners' counsel, the Court impleaded the Ministry of Electronics and Information Technology (recorded in the order as the "Ministry of Information and Technology") and the Ministry of Law and Justice as respondents, directed notice to them and listed the matter on 1 September 2026.⁵

While the petition was pending, the same Bench decided Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd. on 2 July 2026. That judgment set aside NCLT and NCLAT rulings built on hallucinated precedents, declared zero tolerance for unverified AI citations, and directed the Bar Council to frame disciplinary norms, issues that this petition had raised in the trial court context.⁶ On 3 June 2026 the Supreme Court's AI Committee had also published draft Regulations for Use of Artificial Intelligence in Courts, 2026, which recognise hallucination as a defined risk and provide that an officer cannot invoke "the occurrence of hallucination" to avoid accountability for a palpably incorrect, illegal or harmful decision.⁷

The order is notable for what it treats as the wrongdoing. By stating that reliance on fake judgments is "not an error in the decision making" but misconduct, the Court moved from treating hallucination as a drafting mistake to treating reliance on it as a question of accountability for the adjudicator.² It did so at the admission stage of a petition, and used the occasion to open a broader inquiry rather than merely to decide the petitioners' challenge, while barring the trial court from acting on the Advocate Commissioner's report in the meantime.

Second, the proceeding became the vehicle through which the Court brought several actors into one process: the Bar Council of India for lawyer discipline, the Union Law and IT ministries for national policy, and the Court's own AI Committee for rules on judicial use. The Bench's remark about sovereign LLMs links the problem to India's own foundation-model efforts, because in its reported view general-purpose systems built on open-source algorithms cannot avoid hallucination.³

As of 15 October 2026 the special leave petition is pending. The last recorded listing in the sources reviewed was 1 September 2026, and the outcome of that hearing was not found, nor was any decision on whether the trial court judge faces consequences, any report by the Bar Council of India's expert committee, or any amicus report. The stay on proceeding on the Advocate Commissioner's report was ordered pending disposal of the petition. Readers should check the Supreme Court's case status page for later orders.