CASE NAME: Mr. Deepak s/o Shivkumar Bahry v. Heart & Soul Entertainment Ltd.,
CASE NUMBER: W.P. No. 8390 of 2009 clubbed with Interim Application No. 6969 of 2025
COURT: Bombay High Court
DATE: Reserved on 7th October 2025 and Pronounced on 7th January 2026
BENCH: Hon’ble Mr. Justice M.M. Sathaye
FACTS
Due to multiple bench assignments and adjournments concerning the residential flat eviction under Maharashtra Rent Control Act of 1999, the respondent company has filed their written submissions during a period ranging between February and April 2025. These submissions, prepared without independent verification by party-in-person director Mr. Yasin has showed identifiers such as green-box tick marks, bullet points and repetitive phrasings which are components of machine generated outputs and most importantly, the submissions also cited a caselaw titled “Jyoti w/o Dinesh Tulsiani Vs. Elegant Associates” without providing any citations or judgment copies. Court and law clerks expended substantial time attempting to locate this fabricated judgment before recognizing it was AI-hallucinated. These unverified, AI generated submissions were filed by Mr. Yasin after signing them without any verification which tantamount to depositing of machine generated material, directed to the record of the Court.
ISSUES
- Whether parties utilize AI tools such as ChatGPT for generation of legal submissions bear owners to verify the submissions before judicial filing.
- Whether submissions which are AI generated and unverified containing fabricated case laws constitutes imposition of cost penalties.
- Whether practices such as existence of computer-generated errors, fabrication of citations and AI submissions which disrupt the efficiency of the Court necessitate judicial deterrence by meeting such with financial consequences.
- Whether advocates or parties which use AI assistance must cross verify references to ensure genuine existence of cited authorities.
LEGAL PROVISIONS
- High Court Rules of Court: General principles requiring verified, accurate submissions to judicial authority.
- Code of Civil Procedure, 1908: Provisions regarding court conduct and litigation responsibility.
- Constitution of India, Article 227: Court’s supervisory jurisdiction extending to regulation of proceedings ensuring proper justice administration.
- Bar Council of India Standards: Professional conduct requirements applicable to advocates and parties submitting court materials.
ARGUMENTS
PETITIONER:
The counsel on behalf of the petitioner has submitted that the respondent has filed AI generated unverified submissions, which constitute to an abuse of Court process and to the fabricated case or reference is a classic case of machine hallucination, wherein, AI systems invent non-existent authorities based on the information given in the input prompt. It was also argued that submission of such materials without manual verification causes waste of time, judicial resources, and obstructs swift delivery of justice while undermining the efficiency of the Court’s functioning.
RESPONDENT:
Mr. Yasin, party-in-person, contended AI tool utilization in legal research was permissible innovation. He characterized AI as a legitimate research assistance mechanism.
ANALYSIS
Hon’ble Justice Sathaye’s judgment goes on to recognize that AI technology can be utilized for legitimate research assistance potential while explicitly quoting that “if an AI tool is used in aid of research, it is welcome.” However, the judgment went onto to stringent verification responsibility while utilizing AI. The Court identified obvious AI markers in the submissions of the respondent such as existence of green-box tick marks, bullet point structures, formulations in repetitive manner and fabricated caselaw citations. Hon’ble Justice Sathaye went to emphasize that the Court strongly recommended that the submissions are presented using AI tools, such as ChatGPT. The judge went on to elaborate that the caselaw which was mentioned in the submissions had neither citation details nor the judgment copies which is a classic case of AI hallucination that generates non-existent judgments.
Justice Sathaye emphasized by saying “This Court strongly feels that the submissions are prepared using an AI tool such as Chat GPT or alike.” The fabricated case of Jyoti w/o Dinesh Tulsiani Vs. Elegant Associates. for which neither citation details nor judgment copy existed show the way AI systems generate nonexistent authorities.
Justice Sathaye articulated the binding principle by stating “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.” The Court condemned dumping unverified material, stating this practice “must be deprecated and nipped in the bud. This is not assistance to the Court. This is a hurdle in swift delivery of justice.”
He sought three additional hours for arguments two days before summer vacation, necessitating post-vacation rescheduling. Subsequently, after full argument completion before Justice N.J. Jamadar, he again sought adjournment. The matter required complete re-argument before Justice Sathaye. This “precious judicial time of three benches” was substantially wasted, directly attributable to respondent’s AI-generated submissions creating confusion requiring clarification.
JUDGMENT
Writ Petition allowed; revisional order set aside; eviction confirmed; possession directed to petitioner immediately with execution staying indefinitely. Interim Application No. 6969 dismissed.
COSTS IMPOSED
While addressing a significant matter regarding AI misuse, Justice Sathaye directed the respondent to pay costs worth Rs.50,000/- to High Court Employees Medical Fund a period of two weeks from the date of order and submit the proof of payment in the Registry. Disposition of cost penalty represents the first ever substantial judicial penalty for AI generated unverified submissions to judicial bodies. The imposition of an amount of Rs.50,000/- as a fine, reflects the seriousness of the court while handling activities which disrupt the efficiency and functioning of the judicial process. The direction of the cost reaching the High Court Employees Medical Fund ensures for the disciplinary cost to serve institutional welfare.
Hon’ble Justice Sathaye has established that escalation can be made in several ways including imposing of costs on unrepresented party for their advocates resorting to unverified AI submissions, wherein, he clearly laid down that if any advocate is found to be indulging in such practice and even stricter action based on the directions of Bar Council will follow.
CONCLUSION
This judgment goes on to establish a comprehensive jurisprudence on AI tool accountability. By legitimizing AI research assistance, the judgment goes on to impose a binding verification requirement that parties using AI must independently confirm material genuineness, accuracy of citations and authority relevance before submitting it to judicial bodies. The imposition of a Rs. 50,000/- as fine is representative of a deterrent approach towards unverified AI-generated filings. This judgment provides a clear signal that AI innovation must be functioning in a harmonized manner with verification ethics and the failure of which leads to cost consequences and disciplinary actions. The judge clearly lay down that the courts will not tolerate practices which disrupt the efficiency of the system, regardless of technological sophistication.
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Find the true copy of the Judgement here: Mr. Deepak s/o Shivkumar Bahry Versus Heart & Soul Entertainment Ltd.
