--- title: "AI legal research in India without citation risk | Vakilat" description: "What Indian courts said in 2025 and 2026 about fake AI citations, six checks before you cite an AI-found judgment, and the proposed rule on declaring AI use." url: https://www.vakilat.io/guides/ai-legal-research-india --- Guide # Using AI for legal research in India without citation risk Last updated 14 October 2026 In 2026 the Supreme Court held that citing an AI-generated judgment without checking it is misconduct by the advocate, and that a decision resting on one is “no decision in the eyes of the law”. AI can still speed up research. This guide sets out what the courts have said, six checks to run before you cite anything an AI tool found, and the declaration the Court has proposed for filings prepared with AI. ## What the courts have said 1. 19 July 2025 · High Court of Kerala **Policy Regarding Use of Artificial Intelligence Tools in District Judiciary, Official Memorandum HCKL/7490/2025-DI-3:** AI tools may never be used to arrive at findings, reliefs, orders or judgments. Every citation an AI tool produces must be checked by the judicial officer, and courts keep an audit of each use of AI with the human checking done. Cloud tools such as ChatGPT are to be avoided, since their providers may use case facts or privileged communications typed into them. 2. 25 September 2025 · High Court of Delhi **Greenopolis Welfare Association v. Narender Singh, CM(M) 1909/2025:** The petition was dismissed as withdrawn. Counsel for the respondents said they would take appropriate steps and told the court: > “some of the judicial precedents cited on behalf of petitioner do not even exist and in some of the precedents, the quoted portions do not exist” > Order, para 1 3. 27 February 2026 · Supreme Court of India **Gummadi Usha Rani v. Sure Mallikarjuna Rao, SLP (C) No. 7575/2026:** A trial court decided objections to a commissioner's report by relying on four judgments that do not exist. The Supreme Court directed the trial court not to act on the report, issued notice to the Attorney General, the Solicitor General and the Bar Council of India, and appointed senior counsel to assist it. > “a decision based on such non-existent and fake alleged judgments is not an error in the decision making. It would be a misconduct and legal consequence shall follow.” > Order, para 7 4. 3 June 2026 · Supreme Court of India **Draft Regulations for Use of Artificial Intelligence in Courts, 2026, AI Committee, Supreme Court of India:** Published for comment, with the last date later extended to 15 July 2026. Regulation 43 would require a party or advocate who uses AI to prepare a pleading, document or evidence to declare it when filing. 5. 2 July 2026 · Supreme Court of India **Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd., Civil Appeal No. 11950 of 2025, 2026 SCC OnLine SC 1258:** The NCLT had admitted an insolvency application relying on its own research, which cited AI-generated judgments that do not exist, and the NCLAT did not catch them. The Supreme Court set aside both orders and directed the Bar Council of India to frame guiding principles for advocates, with the disciplinary action that follows a breach. > “It is a misconduct on the part of an advocate to cite such judgments without verification.” > Para 7 6. 2 September 2026 · Supreme Court of India **Vijay Ghanshyam Gadiya v. Union of India, 2026 INSC 947:** A customs officer imposed a penalty of ₹425.28 crore relying on case law that was either non-existent or did not lay down what was attributed to it. The Supreme Court set aside the penalty order and the High Court's order and sent the case to another officer of the same rank. > “assistance can never be substituted for adjudication. AI may well serve as training wheels but entrusting it with the pilot's seat would be both imprudent and dangerous.” > Para 6 ## What it means when you cite The rule is about citing without checking. In Pooja Ramesh Singh the Supreme Court said its judgment has no bearing on the rightful use of AI; what it condemns is presenting fake or hallucinated material as if it were a precedent. The responsibility stays with whoever places the citation before the court. Two kinds of error turn up in these cases. Some citations point to judgments that do not exist, like the four in Gummadi Usha Rani. Others name a real judgment for a proposition it does not lay down, or quote words it does not contain, as in Gadiya and Greenopolis. The second kind survives a quick search for the case name, so it needs more care. ## Six checks before you cite 1. Open the judgment itself. Find it on the Supreme Court's or the High Court's website, or in a law report, and confirm the parties, the date, the court and the citation. A case name that appears nowhere official is the clearest warning sign. 2. Read the paragraph you rely on. Check that it holds what you are citing it for, and quote only words you can see on the page. A summary from an AI tool tells you where to read; the paragraph is what you cite. 3. Check the bench and what came later. Note the bench strength, whether the point is the ratio or a passing remark, and whether a later or larger bench has overruled or narrowed it. 4. Check which law applies to your dates. Section numbers changed on 1 July 2024, when the BNS, BNSS and BSA replaced the IPC, CrPC and Evidence Act, and older judgments cite the old sections. Our [old and new sections](https://www.vakilat.io/law) give the counterpart of every section and the rule on which code applies. 5. Keep a note of what you checked. Record the tool you used, the judgments you opened and the paragraphs you read. The Kerala policy already asks courts to keep such a record, and the draft regulations would let a court ask you for it. 6. Keep client confidences out of general chatbots. Before you type facts from a matter into any AI tool, find out where it stores what you type and whether it trains on it. The High Court of Kerala told its courts to avoid cloud chatbots for this reason. ## Declaring AI use in court Regulation 43(3) of the draft would require a party or legal representative who uses an AI tool to prepare or submit a document, pleading or evidence to declare it when filing, in the format of Annexure I. Under regulation 43(4) the court could ask which AI system was used, how much it did, and what steps were taken to check its output. Regulation 43(6) would leave the person who files fabricated or inaccurate AI-generated material fully responsible for it, with no defence that an AI produced it. The regulations are a draft. On 2 September 2026 the Supreme Court described them as yet to be finalised (Gadiya, para 6), and in July it directed the Bar Council of India to frame guiding principles for advocates. Check your court's current practice directions and any Bar Council circular before you file. The note from check 5 answers the questions a court could ask. ## Where Vakilat fits Vakilat is an AI research assistant for Supreme Court of India judgments, built around checks 1, 2 and 5. You ask in plain English, and each authority in the answer is a judgment Vakilat holds, opened at the paragraph it relies on. Ordinary code checks each cited statement against the stored judgment and each quotation against its paragraph, a second AI model reads the draft against the cited paragraphs, and a statement that fails a check is marked for you. Each answer comes with a citation report you can keep as your note. It does not replace your reading. It can make mistakes, which is why every answer shows its checks. It covers the Supreme Court only for now. It reads documents you attach as facts from your file and names the page it relies on. Your questions and documents are not used to train AI models. [Try it on a question from this week's matter](https://app.vakilat.io): five research runs are free, with no card. ## Sources - Policy Regarding Use of Artificial Intelligence Tools in District Judiciary, Official Memorandum HCKL/7490/2025-DI-3, High Court of Kerala, 19 July 2025. - [Greenopolis Welfare Association v. Narender Singh](https://delhihighcourt.nic.in/app/showFile/1758803716_72d19c3525b2f32e_608_19092025.pdf/2025), CM(M) 1909/2025, High Court of Delhi, 25 September 2025. - Gummadi Usha Rani v. Sure Mallikarjuna Rao, SLP (C) No. 7575/2026, Supreme Court of India, 27 February 2026. - [Draft Regulations for Use of Artificial Intelligence in Courts, 2026](https://allahabadhighcourt.in/Final_draft_with_Notice_v2.pdf), AI Committee, Supreme Court of India, Supreme Court of India, 3 June 2026. - Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd., Civil Appeal No. 11950 of 2025, 2026 SCC OnLine SC 1258, Supreme Court of India, 2 July 2026. - Vijay Ghanshyam Gadiya v. Union of India, 2026 INSC 947, Supreme Court of India, 2 September 2026. Supreme Court judgments and orders are published on the [Supreme Court of India's website](https://www.sci.gov.in). This guide describes published court decisions and is general information, which is no substitute for legal advice on a matter.