Gummadi Usha Rani Vs Sure Mallikarjuna Rao (Andhra Pradesh High Court)
The Andhra Pradesh High Court considered a Civil Revision Petition under Article 227 of the Constitution challenging an order refusing to strike down an Advocate Commissioner’s report submitted in a suit for permanent injunction. The petitioners had sought to set aside the report under Section 151 CPC, alleging that the Advocate Commissioner had acted contrary to the High Court’s earlier directions, failed to obtain assistance from the Town/Mandal Surveyor, and colluded with the plaintiffs. The Trial Court dismissed the application, holding that the Commissioner’s report is only an aid to the court, forms part of the evidence, and allegations of bias or misconduct require proof through evidence at trial rather than mere assertions.
Read SC Judgment in this case: AI-Generated Fake Judgments Amount to Misconduct, Not Mere Error: SC
Before the High Court, the petitioners did not primarily challenge the merits of the Commissioner’s report but contended that the Trial Court’s order relied upon several judicial precedents that were non-existent. It was argued that the order was liable to be set aside since the cited authorities were fictitious and had apparently been generated through an Artificial Intelligence tool.
The High Court called for a report from the Trial Judge regarding the citations. The Judicial Officer explained that the references had been incorporated in good faith after using an Artificial Intelligence tool for the first time. She stated that she believed the citations to be genuine and relevant when preparing the order but was subsequently unable to locate those judgments in official databases or law reports. She acknowledged that the citations had been AI-generated and expressed regret, stating that there had been no intention to misquote or misrepresent legal authorities and that greater care would be exercised in verifying citations from authoritative sources in future. The High Court accepted the report.
