AI-Generated Fake Citations Won’t Vitiate Judicial Order If Legal Reasoning Is Sound: Andhra Pradesh High Court
AI tools at present can assist in summarising information but lack judicial reasoning
The Andhra Pradesh High Court has cautioned courts and legal practitioners against uncritical reliance on Artificial Intelligence tools after it was found that a trial court order cited non-existent case laws generated by an AI platform. However, the High Court clarified that mere reference to fake citations would not automatically invalidate a judicial order if the legal principles applied are otherwise correct.
The Bench observed that AI tools, at their present stage, can assist in organising and summarising information but lack judicial reasoning, moral judgment, and contextual understanding. The Court warned that AI may generate content that appears persuasive but is legally incorrect or entirely fabricated.
Justice Ravi Nath Tilhari while referring to Bandhua Mukti Morcha v. Union of India (1984) 3 SCC 161 and M.P.Rajya Tilhan Utpadak Sahakari Sangh Maryadit, Pachama, District Sehore and others v. Modi Transport Service (2022) 14 SCC 345, thus observed, “This Court does not find any illegality in the impugned order. Merely because non-existing citations were referred due to the use of Artificial Intelligence Tool, without due verification, the order would not be vitiated, when the law stated in the order and its application is correct”.
However, the Court also observed that “…The people who employ AI for legal research should rigorously scrutinize its outputs, including the authorities cited. Such tools may lack access to the complete body of relevant law, may not fully comprehend the query posed, or may overlook material authorities. In such circumstances, AI systems can produce responses that appear persuasive yet are factually or legally incorrect. More concerningly, they may fabricate authorities or cite existing cases that are irrelevant to the issue under consideration”.
Advocate M. Venkata Siva Teja appeared for the petitioner.
The Court was hearing a civil revision petition challenging an order that refused to strike down an Advocate Commissioner’s report on the ground that the trial court had relied on fictitious precedents while deciding the application.
Calling for an explanation, the High Court received a report from the Judicial Officer, who admitted that the citations were AI-generated, used in good faith, and later found to be untraceable in any authoritative legal database. The officer assured greater caution in the future.
Referring to international and Indian precedents, including cases from England and Wales and the Bombay High Court, the Court said that placing fictitious authorities on record causes serious harm, wasting judicial time, misleading courts, and eroding confidence in the justice delivery system.
The bench, however, held that since the trial court had applied settled principles governing the evidentiary value of an Advocate Commissioner’s report, mere mention of incorrect or AI-generated citations did not warrant interference. The commissioner’s report, the Court reiterated, is only a piece of evidence, to be tested during trial through objections and cross-examination.
The Court concluded by stressing that human intelligence must prevail over artificial intelligence, and that judges must independently verify all authorities relied upon, ensuring that judgments are grounded in authentic law and judicial application of mind.
Cause Title: Gummadi Usha Rani and another v. Sure Mallikarjuna Rao and another, Civil Revision Petition No: 2487 OF 2025
Appearances:
Petitioner: M. Venkata Siva Teja, Advocate