What was hallucinated

Fabricated: Case Law | Trial Court's order cited 'Gajanan v. Ramdas ((2015) 6 SCC 223)', which could not be located and was found to have been produced by the AI tool used by the Judicial Officer. || Fabricated: Case Law | Trial Court's order referred to 'Subramani v. M.Natarajan ((2013) 14 SCC 95)', which verification could not locate; the Judicial Officer reported the citation was AI-generated. || Fabricated: Case Law | Trial Court's order cited 'Chidambaram PIllai v. SAL Ramasamy (1071 (2) SCC 68)', which could not be traced and was admitted to be AI-generated. || Fabricated: Case Law | Trial Court's order cited 'Lakshmi Devi v. K.Prabha ((2006) 5 SCC 551)', which the Judicial Officer could not verify and reported as AI-generated.

Sanction teardown · HC Andhra Pradesh, India · 2026-01-25

Gummadi Usha Rani v. Sure Mallikarjuna Rao

What happened

In HC Andhra Pradesh, India, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

Fabricated (Case Law)

Trial Court's order cited 'Gajanan v. Ramdas ((2015) 6 SCC 223)', which could not be located and was found to have been produced by the AI tool used by the Judicial Officer.
Fabricated (Case Law)

Trial Court's order referred to 'Subramani v. M.Natarajan ((2013) 14 SCC 95)', which verification could not locate; the Judicial Officer reported the citation was AI-generated.
Fabricated (Case Law)

Trial Court's order cited 'Chidambaram PIllai v. SAL Ramasamy (1071 (2) SCC 68)', which could not be traced and was admitted to be AI-generated.
Fabricated (Case Law)

Trial Court's order cited 'Lakshmi Devi v. K.Prabha ((2006) 5 SCC 551)', which the Judicial Officer could not verify and reported as AI-generated.

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Not specified in source record.

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/1395/GUMMADI_USHA_RANI_v._SURE_MALLIKARJUNA_RAO.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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