ICICI Bank Ltd. v. Urban Infrastructure Real Estate Ltd. does not exist — a fabricated AI citation

The National Company Law Tribunal relied on “ICICI Bank Ltd. v. Urban Infrastructure Real Estate Ltd., (2019) 16 SCC 528” as precedent in Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd. & Anr. The Supreme Court of India, reviewing the matter on appeal, found this to be a non-existent citation — no such case appears at that Supreme Court Cases reporter volume and page.

What makes this case unusual, and one of the most consequential in this entire database, is the scale of the tribunal's downstream reliance on fabricated authority. This was not one invented citation among many real ones supporting a minor point — the Supreme Court found the NCLT, and by affirmation the NCLAT above it, had relied on multiple AI-generated, non-existent precedents across the proceeding, undermining the reliability of the entire ruling being appealed.

The Supreme Court's response was correspondingly severe: it set aside both the NCLT and NCLAT orders entirely, restored the original Section 7 insolvency petition, held that reliance on unverified AI-generated case law amounts to a subversion of the rule of law, and directed the Bar Council of India to formulate guidance and disciplinary measures for AI-citation practice going forward — a systemic remedy, not just a case-specific correction. Because the underlying error originated in a tribunal's own order rather than a party's brief, this case is also a rare documented instance of AI-hallucinated citations compromising a judicial decision itself, not merely the advocacy in front of it.