What was hallucinated

Fabricated: Case Law | NCLT relied on the citation 'ICICI Bank Ltd. v. Urban Infrastructure Real Estate Ltd., (2019) 16 SCC 528' which the Supreme Court found to be a non-existent citation. || Fabricated: Case Law | NCLT relied on 'V.S. Dempo & Co. Ltd. v. Reliance Communications Ltd., (2021) 10 SCC 176', which the Supreme Court determined is a non-existent citation. || False Quotes: Case Law | NCLT cited Canara Bank v. N.G. Subbaraya Setty & Anr., (2018) 16 SCC 228 but relied on a paragraph not found in the reported judgment. || Fabricated: Case Law | NCLT relied on 'Sarbjit Singh v. Union Bank of India, (2022) 7 SCC 464', which the Supreme Court found to be a non-existent citation. || False Quotes: Case Law | NCLT attributed a non-existent paragraph to 'State Bank of India v. M/s Shree Ram Urban Infrastructure Ltd., 2020 SCC OnLine SC 341'; Supreme Court found the paragraph non-existent and the correct cause title is M. Subramaniam v. S. Janaki, (2020) 16 SCC 728. || False Quotes: Case Law | NCLT cited Everest Kento Cylinders Ltd. v. Union of India (2015) 2 SCC 1 but relied on a paragraph that does not exist in that reported judgment.

Details

The Supreme Court found that the NCLT (and by affirmation the NCLAT) relied on AI-generated, non-existent case law and misattributed paragraphs presented as precedents. The Court held such reliance amounts to a subversion of the rule of law and declared zero tolerance for citing unverified AI-generated precedents, set aside the impugned orders, restored the Section 7 petition, and directed the Bar Council of India to formulate guidance and disciplinary measures.

Sanction teardown · Supreme Court, India · 2026-07-02

Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd. & Anr.

What happened

In Supreme Court, 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)

NCLT relied on the citation 'ICICI Bank Ltd. v. Urban Infrastructure Real Estate Ltd., (2019) 16 SCC 528' which the Supreme Court found to be a non-existent citation.
Fabricated (Case Law)

NCLT relied on 'V.S. Dempo & Co. Ltd. v. Reliance Communications Ltd., (2021) 10 SCC 176', which the Supreme Court determined is a non-existent citation.
False Quotes (Case Law)

NCLT cited Canara Bank v. N.G. Subbaraya Setty & Anr., (2018) 16 SCC 228 but relied on a paragraph not found in the reported judgment.
Fabricated (Case Law)

NCLT relied on 'Sarbjit Singh v. Union Bank of India, (2022) 7 SCC 464', which the Supreme Court found to be a non-existent citation.
False Quotes (Case Law)

NCLT attributed a non-existent paragraph to 'State Bank of India v. M/s Shree Ram Urban Infrastructure Ltd., 2020 SCC OnLine SC 341'; Supreme Court found the paragraph non-existent and the correct cause title is M. Subramaniam v. S. Janaki, (2020) 16 SCC 728.
False Quotes (Case Law)

NCLT cited Everest Kento Cylinders Ltd. v. Union of India (2015) 2 SCC 1 but relied on a paragraph that does not exist in that reported judgment.

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

NCLT and NCLAT judgments set aside

Additional detail

The Supreme Court found that the NCLT (and by affirmation the NCLAT) relied on AI-generated, non-existent case law and misattributed paragraphs presented as precedents. The Court held such reliance amounts to a subversion of the rule of law and declared zero tolerance for citing unverified AI-generated precedents, set aside the impugned orders, restored the Section 7 petition, and directed the Bar Council of India to formulate guidance and disciplinary measures.

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/2514/Pooja_Singh_vs._JK_Bank.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).