The Supreme Court flagged that a party had submitted a compilation containing AI-generated fake judgments — citations that do not exist but were fabricated by an artificial intelligence tool. The Court treated this as a serious matter of professional misconduct, warning that filing non-existent judgments before courts undermines the integrity of judicial proceedings. The incident spotlights a growing global problem of 'AI hallucination' in legal practice, where generative AI tools confidently produce false but plausible-sounding case citations.

This incident engages a foundational principle of court procedure: advocates are officers of the court and owe a duty of candour — they cannot knowingly or recklessly place false material before a judge. When a party or counsel cites a judgment, the court relies on that citation as a genuine precedent. Submitting a fabricated citation — even if the error originates with an AI tool — does not absolve the advocate, because professional responsibility cannot be delegated to software.

The phenomenon the Court is responding to is called 'AI hallucination': large language models sometimes generate realistic but entirely fictitious case names, citation numbers, and excerpts. Several courts globally — including in the United States (Mata v. Avianca, 2023) and Canada — have sanctioned lawyers for filing AI-hallucinated citations without verification.

For Indian law, the incident connects to Bar Council of India Rules on professional conduct (Part VI, Chapter II), which prohibit advocates from making false statements or misleading the court. It also raises questions about whether courts should require disclosure when AI tools are used in preparing submissions.

For CLAT PG, the examiner is likely to test: (1) the name and principle of the relevant duty owed by advocates to the court; (2) the concept of 'AI hallucination'; (3) the procedural consequence — contempt or professional misconduct — for filing fabricated material; and (4) how this connects to the open-court and transparency principles the Court has articulated in earlier judgments.