Fake Case Law, AI Submissions: Bombay HC Imposes Rs50,000 Cost on Litigant

Moneylife Digital Team 16 January 2026

Economy & Nation

The Bombay High Court (HC) has strongly deprecated the practice of filing unverified, artificial intelligence (AI)-generated legal submissions after a litigant relied on a non-existent court judgment, prompting the Court to impose Rs50,000 as costs to High Court Employees Medical Fund.

Justice MM Sathaye, while hearing a dispute arising from a leave and licence agreement over a flat in MHADA in Mumbai’s Oshiwara area, admonished the respondent for what he described as 'dumping' machine-generated content on the Court, holding that such conduct hampers the efficient administration of justice.

He says, "From the overall tenor of the written submissions and a few give-away features, such as green-box tick-marks, bullet-point-marks and repetitive submissions, this Court strongly feels that the submissions are prepared using an AI tool such as ChatGPT or alike. A strong pointer is seen from a reference made to one alleged case law, 'Jyoti w/o Dinesh Tulsiani vs Elegant Associates'. Neither citation is given nor a copy of judgement is supplied by the Respondent. This Court and its law clerks were at pains to find out this caselaw but could not find. This has resulted in a waste of precious judicial time. 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 or computer is really relevant, genuine and in existence. This Court finds that the Respondent has simply filed written submissions by signing them without verifying its contents."

"This practice of dumping documents or submissions on the Court and making the Court go through irrelevant or non-existing material must be deprecated and nipped at bud. This is not assistance to the Court. This is a hurdle in swift delivery of justice. This Court will not take such practices kindly and it is going to result in costs. If an advocate is found to be indulging in such practice, then even stricter action of referring to Bar Council may follow," the HC says in its order.

The Court was examining written submissions filed by Mohammed Yasin, director of Heart & Soul Entertainment Ltd, which occupied the flat owned by film producer Deepak Shivkumar Bahry. During scrutiny, the HC found that the submissions by Heart & Soul Entertainment bore several 'give-away' features typical of artificial intelligence tools such as ChatGPT, including distinctive tick marks, repetitive phrasing and generic structuring.

More significantly, the submissions cited the judgment titled Jyoti w/o Dinesh Tulsiani vs Elegant Associates, a case that the Court and its law clerks were unable to trace despite extensive verification.

Justice Sathaye was particularly critical of the fact that Mr Yasin had signed and filed the written submissions without verifying their contents, despite relying on them to seek serious reliefs before the court.

The dispute itself related to a leave and licence arrangement concerning a residential flat in a MHADA complex at Oshiwara, which was used by Heart & Soul Entertainment. The company, represented by Mr Yasin, had also sought perjury and contempt action against the opposite party.

The Court dismissed that application and directed Heart & Soul Entertainment to pay Rs50,000 as costs to the High Court Employees Medical Fund within two weeks.

Justice Sathaye held that Heart & Soul Entertainment’s overall conduct, including repeated adjournments and reliance on a fabricated citation, justified the imposition of costs to deter such practices at the threshold.

Comments