Bombay HC Fines Litigant ₹50,000 For Citing Fake AI-Generated Judgment In Written Submissions

Mumbai, Jan 16: Deprecating the growing practice of filing unverified, AI-generated legal submissions, the Bombay High Court recently imposed costs of Rs 50,000 on a litigant for relying on a non-existent judgment in his written arguments, holding that such conduct obstructs the swift delivery of justice.

Court flags fake citation

Justice Milind Sathaye, on January 7, strongly criticised Mohammed Yasin, director of Heart & Soul Entertainment Ltd, a film production company, for “dumping” machine-generated content on the court without verifying its authenticity.

The court found that the written submissions bore clear “give-away” features typical of artificial intelligence tools such as ChatGPT, including repetitive phrasing, bullet points and distinctive tick marks.

A key concern for the court was Yasin’s reliance on an alleged judgment titled Jyoti w/o Dinesh Tulsiani vs Elegant Associates, which neither the court nor its law clerks could trace. No citation or copy of the judgment was provided.

Responsibility lies with users

“If an AI tool is used in aid of research, it is welcome; however, there is great responsibility upon the party, even an advocate using such tools, to cross verify the references and make sure that the material generated by the machine/computer is really relevant, genuine and in existence,” Justice Sathaye observed.

The court noted that Yasin had filed the written submissions merely by signing them, without verifying their contents. “This practice of dumping documents/submissions on the court and making the court go through irrelevant or non-existing material must be deprecated and nipped at bud,” the judge said, adding that such conduct was “not assistance to the court” but rather “a hurdle in swift delivery of justice”.

Background of the dispute

The dispute arose from a leave and licence arrangement concerning Flat No. 105 in a MHADA complex at Oshiwara, Mumbai, owned by film producer and director Deepak Shivkumar Bahry. Heart & Soul Entertainment Ltd, represented by Yasin, was inducted as a licensee under a registered agreement dated January 5, 2007, for residential use.

Bahry approached the court under Section 24 of the Maharashtra Rent Control Act, alleging breach of licence conditions and unlawful retention of the flat after termination of the agreement in May 2008. Yasin, appearing in person, had earlier filed a civil suit claiming an alleged agreement to transfer the flat — a claim consistently denied by the petitioner.

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Costs imposed

Dismissing the respondent’s application seeking perjury and contempt action, the High Court directed Yasin to deposit Rs 50,000 with the High Court Employees Medical Fund within two weeks. The court held that repeated adjournments and reliance on fake citations warranted costs “to deter such practices at the threshold”.

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