Archive · 29 Jul 2026
Delhi High Court Warns Against AI-Generated Hallucinated Citations
The Delhi High Court recently made a big decision.
They found out that a lower court's order used fake or made-up legal cases to support its decision.
The High Court said this is a serious problem and can be seen as cheating the justice system.
They warned that anyone using fake cases, whether made by AI or by themselves, should be punished.
The High Court then canceled the lower court's order and sent the case back for a new decision.
The person who made the original order had already retired, so they couldn't be punished.
Delhi High Court set aside an order by the Commissioner of Income Tax (Appeals) for relying on six non-existent judicial precedents.
The court warned against the use of hallucinated citations, whether generated by AI or self-generated, and called for strict action.
The EPFO challenged the order, arguing that the appellate authority based its decision on non-existent judgments.
The court found that the citations were inserted without verification due to a heavy workload and reliance on an inspector.
The matter was remanded back to the appellate authority for a fresh decision, and no disciplinary action was taken against the retired author.
- Who
- Delhi High Court, Commissioner of Income Tax (Appeals), Employees’ Provident Fund Organisation (EPFO)
- What
- Delhi High Court set aside an order due to reliance on non-existent citations and warned against the use of hallucinated judgments.
- When
- The matter was heard in May, with the final decision recently announced.
- Where
- Delhi High Court, India
- Why
- The court found that the order relied on six judicial precedents that did not exist, which it deemed fraudulent and a threat to the justice system.
Court's Stance
Commissioner's Defense
Use of Non-Existent Citations
Court's Stance
The Delhi High Court condemned the use of non-existent or hallucinated citations, deeming it fraudulent and a threat to the justice system.
Commissioner's Defense
The Commissioner of Income Tax (Appeals) attributed the error to an overburdened workload and reliance on an inspector for citations.
- Court
- Delhi High Court
- Bench
- Justices Dinesh Mehta and Rajneesh Kumar Gupta
- Non-Existent Cases Cited
- Six cases, including CIT v. Outstanding Industrial Enterprises and CIT v. Orissa Corporation (P) Ltd.
- Action Taken
- Order set aside and matter remanded for fresh decision
- Disciplinary Action
- Not initiated due to the author's retirement