Andhra Pradesh High Court Upholds Judicial Order Citing AI-Generated Non-Existent Case Law
The Andhra Pradesh High Court has delivered a landmark ruling addressing the growing use of artificial intelligence in judicial proceedings. In a significant decision, the court held that a judicial order does not become invalid merely because it references non-existent citations or rulings generated by AI, provided the legal principles applied are otherwise correct and align with settled law.
Court's Rationale and Observations
Justice Ravi Nath Tilhari made this observation while dismissing an appeal challenging a trial court's order that refused to strike down an advocate commissioner's report in a property dispute. The petitioners had contended that the trial court relied on non-existent rulings in its decision.
"If the learned Trial Court has considered the correct principles of law and its application to the facts of the case is also correct, mere mentioning of incorrect or non-existent rulings/citations in the order cannot be a ground to set aside the order," the court noted in its order.
Background of the Case
The dispute originated from a civil suit for permanent injunction pending before a Vijayawada court. An advocate commissioner was appointed following high court directions to determine whether the suit property fell within land purchased by the first defendant. After the commissioner submitted a report, the defendants sought to have it struck down, alleging collusion with plaintiffs and failure to follow proper procedures.
The trial court rejected these objections, maintaining that an advocate commissioner's report serves only as an aid to the court and must be tested during trial through evidence and cross-examination. However, while delivering this order, the trial court cited judgments that later proved to be AI-generated and non-traceable.
Judicial Officer's Explanation
The judicial officer involved reported that she had used an artificial intelligence tool for the first time, which displayed those references. Believing them to be genuine and relevant, she incorporated the citations into her order. She clarified that there was no intention to misquote or misrepresent rulings and that the mistake occurred solely due to reliance on an automated source.
The officer expressed commitment to exercising greater caution in verifying citations from authoritative sources in the future, highlighting the importance of human oversight in AI-assisted legal research.
Court's Warning About AI in Legal Research
Justice Tilhari observed that while AI tools can be beneficial for legal research, their unregulated use may give rise to serious concerns. The court emphasized that judicial interference would be warranted if:
- The legal principle applied is not settled law
- Its application is flawed due to reliance on non-existent, AI-generated rulings
"If the principle of law applied is not the law of the land or its application in a given case is faulted because of relying on non-existent rulings generated by AI, then the case for interference would be made out," the order stated.
Potential Risks of Unverified AI Use
The court highlighted several risks associated with uncritical reliance on AI for legal research:
- AI tools may lack access to the complete body of relevant law
- They may not fully comprehend the legal query posed
- They might overlook material authorities or precedents
- They can produce responses that appear persuasive but are factually or legally incorrect
- They may fabricate authorities or cite irrelevant existing cases
More concerningly, the court noted the serious risk of damage to judicial reputation when judges' names are falsely attributed to fictitious opinions, as well as potential harm to parties associated with fictional conduct.
Broader Implications for Legal Practice
The Andhra Pradesh High Court's ruling establishes an important precedent for how courts should handle errors arising from AI-assisted legal research. The decision underscores that:
- Legal professionals using AI must rigorously scrutinize its outputs, including verifying all cited authorities
- The substance of legal reasoning takes precedence over citation errors when principles are correctly applied
- Unregulated AI use may violate privacy and damage public confidence in judicial decision-making
The court maintained that the commissioner's report remains a piece of evidence to be considered at final hearing, subject to objections and evidence on record. The petitioners retain the opportunity to challenge the report's correctness through cross-examination and other legal means.
This ruling comes at a time when Indian courts are increasingly grappling with the implications of artificial intelligence in legal proceedings, balancing technological benefits against the need for accuracy and reliability in judicial processes.
