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Vijay Ghanshyam Gadiya v. Union of India & Anr.

Court
Supreme Court of India
Jurisdiction
India
Decided
2026-09-02
AI tool
Implied
Outcome
The High Court order and Order-in-Original imposing the penalty were set aside; proceedings were remanded for fresh determination by a different officer of the same rank.
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | The Customs authority relied on case laws that the Supreme Court verified as non-existent or carrying fake citations. || Misrepresented: Case Law | The Customs authority relied on existing case laws for propositions that those cases did not actually establish; the Supreme Court characterized this as AI hallucination.

Details

The Supreme Court found that the Customs authority’s Order-in-Original relied on judgments and articles apparently generated using AI. Its verification showed that some authorities were non-existent or had fake citations, while other existing authorities did not support the propositions attributed to them. Treating reliance on such dubious material as fatal to the order, the Court set aside both the High Court judgment and the penalty order and remanded the matter for a fresh decision. The Court left it to the appointing authority to consider action against the author of the order.

Sanction teardown · Supreme Court of India, India · 2026-09-02

Vijay Ghanshyam Gadiya v. Union of India & Anr.

What happened

In Supreme Court of India, 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)
    The Customs authority relied on case laws that the Supreme Court verified as non-existent or carrying fake citations.
  • Misrepresented (Case Law)
    The Customs authority relied on existing case laws for propositions that those cases did not actually establish; the Supreme Court characterized this as AI hallucination.

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

The High Court order and Order-in-Original imposing the penalty were set aside; proceedings were remanded for fresh determination by a different officer of the same rank.

Additional detail

The Supreme Court found that the Customs authority’s Order-in-Original relied on judgments and articles apparently generated using AI. Its verification showed that some authorities were non-existent or had fake citations, while other existing authorities did not support the propositions attributed to them. Treating reliance on such dubious material as fatal to the order, the Court set aside both the High Court judgment and the penalty order and remanded the matter for a fresh decision. The Court left it to the appointing authority to consider action against the author of the order.

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/3013/Vijay_Ghanshyam_Gadiya_v_Union_of_India_.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/3013/Vijay_Ghanshyam_Gadiya_v_Union_of_India_.pdf

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