India's Supreme Court records an objection to an AI-fabricated case compilation

Key takeaways

• Paragraph 74 reports the respondents' objection that the compilation was "replete with AI generated non-existent judgments".
• The Advocate-on-Record is recorded as shifting blame to the appellants; senior counsel took the blame and prayed for forgiveness.
• Exemplary costs were proposed, then deleted as "no order as to costs" because the first appellant had died.
• Both appeals were dismissed on the insolvency merits.

What did the Supreme Court record about the compilation of judgments?

The main appeals concerned insolvency. Two appeals under Section 62 of the Insolvency and Bankruptcy Code, 2016 challenged National Company Law Appellate Tribunal orders upholding the admission of Section 7 petitions against GSTAAD Hotels Pvt. Ltd. and Neo Capricorn Plaza Pvt. Ltd. The AI point appears only at the end, in paragraph 74, which opens: "Before parting, we wish to advert to an undesirable incident that transpired in course of hearing."

According to that paragraph, the appellants placed a compilation of judgments on record and the respondents "raised immediate serious objection". In the Court's account of their position, "the compilation was replete with AI generated non-existent judgments." The paragraph does not list the citations at issue, name the counsel involved, or name the AI tool.

How did counsel respond, and what happened to the costs?

The Court says the Advocate-on-Record, "facing the Court's query", sought to shift the entire blame on the appellants while feigning ignorance of what the compilation contained. Learned senior counsel then "sought to take the blame on himself and prayed for forgiveness on behalf of the appellants."

The Court says it heard the appeal on the merits while keeping the respondents' objection open. That objection was that the appellants, by reason of such conduct, do not deserve a hearing on merits. The paragraph states that "Exemplary costs were proposed to be imposed while coming down heavily on the appellants." The Court was then informed of the first appellant's death, and for that reason the order requiring payment of costs was deleted and replaced with "no order as to costs". Paragraph 73 separately records no order as to costs. The paragraph records no referral to a bar council or other body.

Did the AI problem affect the outcome of the appeals?

The judgment does not suggest it did. In paragraph 72 the Court found no merit in either appeal and dismissed both, upholding the National Company Law Tribunal's orders of 8 July 2025 as affirmed by the Appellate Tribunal on 19 August 2025, with the insolvency resolution process to proceed in accordance with law. The summary of conclusions in paragraph 71 deals only with the Code, including how default is proved at the Section 7 stage. For lawyers, the lesson is not about this client's fate. A party whose compilation is challenged can still be heard on the merits, and the Court still found it worth recording the incident and the proposed costs in a reportable judgment.

What does this mean for advocates and Advocates-on-Record in India?

A practical control, offered as our recommendation and not as a reading of paragraph 74, is to require named sign-off before filing. The Court records that the Advocate-on-Record, when questioned, tried to attribute the problem to the appellants, and that the Court's reaction was to propose exemplary costs. The judgment does not say which role bears responsibility, and it does not set a standard of care. It does not require disclosure of AI use.

Other Indian items on this site cover related ground, including the Supreme Court's Gadiya customs order and the Court's remarks on advocate misconduct. This article covers a different case, Raheja v. Omkara, decided on 15 October 2026.

What should litigation teams do now?

The judgment prescribes no AI-specific steps, so these steps are our suggestions, not requirements.

• Open every authority in a compilation and match the party names, citation and quoted passage against a reliable law report before filing.
• Name one person who signs off the compilation, and keep a short record of what was checked.
• If a generative tool helped to gather authorities, treat its output as unverified until each item is confirmed.
• If an opponent challenges a citation, be ready to answer the Court directly and to say who prepared the document.

What are the key dates and parties?

What we did not verify

What we opened: the signed 50-page judgment PDF (2026 INSC 1134), as hosted by LiveLaw, including paragraphs 71 to 74, on 25 October 2026 (UTC).

What we did not open: the copy on the Supreme Court of India website, the compilation itself, the respondents' written objection, any record of which citations were non-existent, and any later order or bar council action. We do not know which AI tool was used or how many citations were affected. LiveLaw's headline names GSTAAD Hotels and Neo Capricorn, the corporate debtors in the same appeals.

What we refuse to claim: that the Court itself verified each citation as fake, that any lawyer was sanctioned, found guilty of misconduct or referred to a regulator, or that the judgment sets a rule for AI use in filings.

Related briefings

• AI Regulation News hub
• Asia-Pacific AI regulation tracker
• Attorneys and AI regulation
• Supreme Court of India, Gadiya customs order on AI-hallucinated citations
• Supreme Court of India on AI-hallucinated citations and advocate misconduct
• Punjab and Haryana High Court on an AI fabrication defence
• Supreme Court of India draft rules on AI in courts