Indian Journal for Research in Law and Management

Advancing Law and Management

ISSN No. : 2583-9896

Judicial Misconduct in the Age of Al: The Supreme Court on Fake, Al-Generated Case Law in Gummadi Usha Rani v. Sure Mallikarjuna Rao

Cite this Article

Shubhendu Bhushan Tripathi (2026). Judicial Misconduct in the Age of Al: The Supreme Court on Fake, Al-Generated Case Law in Gummadi Usha Rani v. Sure Mallikarjuna Rao. The Indian Journal for Research in Law and Management, Volume III(Issue 6). Retrieved from https://ijrlm.com/journal/judicial-misconduct-in-the-age-of-al-the-supreme-court-on-fake-al-generated-case-law-in-gummadi-usha-rani-v-sure-mallikarjuna-rao/

Abstract

The case of Gummadi Usha Rani & Anr. V. Sure Mallikarjuna Rao & Anr. (2026) highlights a serious institutional concern in the Indian judiciary about the use of Artificial Intelligence in adjudication. The controversy is less about who ultimately succeeds in the property dispute and more about the integrity of the decision‑making process: the Trial Court relied on four judgments that turned out to be non‑existent, AI‑generated “synthetic” citations. These citations appeared facially authentic, with party names, SCC volumes and years, but could not be traced in any standard law report or database. The High Court of Andhra Pradesh acknowledged that the citations were AI‑generated and recorded a word of caution, yet chose to affirm the Trial Court’s order on the merits. On 27 February 2026, the Supreme Court treated the matter as one of “considerable institutional concern”, stayed further reliance on the Advocate Commissioner’s report, issued notice to top law officers and the Bar Council of India, and appointed a senior advocate as amicus to examine the systemic consequences of AI‑generated fake case law. The order underscores that decisions based on non‑existent, AI‑generated judgments are not mere errors but “misconduct,” with legal consequences to follow, thereby foregrounding accountability in the age of AI‑assisted adjudication.

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The Indian Journal for Research in Law and Management
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2583-9896
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