Gummadi Usha Rani & Anr. Vs Sure Mallikarjuna Rao & Anr. (Supreme Court of India)
The proceedings arose from a suit for permanent injunction in which the Trial Court appointed an Advocate Commissioner to inspect the property and submit a report. The defendants objected to the Advocate Commissioner’s report, alleging that the Commissioner had acted contrary to the High Court’s earlier directions, had failed to take the assistance of the Town/Mandal Surveyor, and had colluded with the plaintiffs. The Trial Court rejected those objections on 19.08.2025, holding that the Commissioner’s report is an aid to the court, is to be treated like any other piece of evidence, and that allegations of collusion or misconduct required proof through evidence and cross-examination rather than mere assertions. While doing so, the Trial Court relied upon four judicial precedents which were subsequently found to be non-existent.
Read HC Judgment in this case: AI-Generated Fake Citations Alone Do Not Vitiate Judicial Orders: AP HC
Before the Andhra Pradesh High Court, the defendants challenged the Trial Court’s order primarily on the ground that it relied upon fake and non-existent authorities. The High Court called for a report from the Trial Judge. The Judicial Officer explained that the citations had been generated through an Artificial Intelligence tool, had been incorporated in good faith, and were later found to be non-existent after verification. She stated that there had been no intention to misquote judicial precedents and undertook to verify citations from authoritative sources in future. The High Court accepted the report.
