V.S. Dempo & Co. Ltd. v. Reliance Communications Ltd. does not exist — a fabricated AI citation

“V.S. Dempo & Co. Ltd. v. Reliance Communications Ltd., (2021) 10 SCC 176” was one of several citations the National Company Law Tribunal relied on in the underlying proceeding that reached the Supreme Court of India in Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd. & Anr. The Supreme Court determined this too is a non-existent citation.

This case name did not stand alone: the tribunal's order also cited a fabricated Sarbjit Singh v. Union Bank of India and a fabricated ICICI Bank Ltd. v. Urban Infrastructure Real Estate Ltd. in the same proceeding, plus several instances of real cases quoted with paragraphs that do not actually appear in the reported judgments. Taken together, the record shows a tribunal opinion built on a mix of invented precedent and misquoted real precedent — a pattern that, once identified, called the entire order's reasoning into question rather than just one footnote of it.

The Supreme Court's ultimate remedy applied to the whole pattern rather than this citation individually: it set aside the NCLT and NCLAT orders, restored the underlying Section 7 petition, and directed the Bar Council of India to develop disciplinary guidance specifically addressing AI-generated case law in Indian legal practice. The Supreme Court's opinion is now regularly cited in Indian legal commentary as the leading domestic authority on AI-citation discipline, occupying roughly the same reference-point role that Mata v. Avianca holds in U.S. practice.