Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd.

Supreme Court of India, 2 July 2026, 2 judges, 2026 INSC 668

A decision that relies on fake or hallucinated AI-generated material as precedent is no decision in law; the NCLT admission order and the NCLAT appeal order were set aside and the insolvency application restored for fresh decision.

Facts

The appellant was a suspended director of Essel Infraprojects Ltd., corporate guarantor of loans taken by Pan India Utilities Distribution Company Ltd. from Jammu and Kashmir Bank Ltd. After defaults, the Bank applied under Section 7 of the Insolvency and Bankruptcy Code, 2016. The NCLT, Mumbai admitted the application on 28.08.2024. The NCLAT dismissed the appellant's appeal on 11.09.2025, referring to six Supreme Court decisions relied upon by the NCLT. Before the Supreme Court the appellant pointed out that these citations were fake and non-existent, probably AI-generated. It was not disputed: the Court's own examination found non-existent citations and non-existent paragraphs attributed to real judgments. The Bank filed an affidavit that its counsel had not cited them and that they came from the adjudicating authority's own research.

Questions before the Court

What is the legal status of a decision of a court or tribunal that relies on non-existent, fake or hallucinated AI-generated material as precedent?
Could the NCLT order admitting the Section 7 application and the NCLAT order affirming it stand when they rested on such material?

What the Court held

Courts must adopt zero tolerance for producing, citing or using AI-generated precedents without verification. A decision relying on fake or hallucinated AI-generated material as precedent is no decision in the eyes of the law, whether the material had a direct or indirect bearing, and must be set aside even if an iota of such material enters the decision-making.
It is misconduct for an advocate to cite such judgments without verification, and a serious lapse for a judge to rely on them. The judgment does not bear on the rightful use of AI, only on presenting or relying on fake material as if it were a court precedent.
The Bar Council of India was directed to constitute a committee, deliberate on members of the bar submitting fake and hallucinated material as precedents, and prescribe a guiding principle to prevent it along with the disciplinary action that will follow a violation.
As it was undisputed that the NCLT relied on non-existent judgments and AI-generated paragraphs wrongly attributed to real citations, the NCLT order of 28.08.2024 and NCLAT order of 11.09.2025 were set aside. The Section 7 application was restored, to be decided afresh on merits, preferably within two weeks, with status quo meanwhile.

Why it matters

The judgment declares that a judicial or tribunal decision resting on fake or hallucinated AI-generated precedents is no decision in law and must be set aside, regardless of how much the material influenced the result. It treats unverified citation of such material as misconduct by advocates and a serious lapse by judges, insists on a human in the loop at every stage of adjudication, and directs the Bar Council of India to frame norms and disciplinary consequences.

In the Court's words

Copied from the official judgment; each passage links to its page.

“More than the inevitable consequence of setting aside such judgments, what is significant for our decision-making is our resolve to adopt AI technology in aid of adjudication, while at the same time asserting and declaring total and absolute control over adjudication, with a human in the loop at every stage.”

Page 1 of the judgment

“It is necessary for Courts to adopt a zero-tolerance mode for producing, citing or using AI-generated precedents without verification. It is a misconduct on the part of an advocate to cite such judgments without verification. Equally, it is a serious lapse if a judge relies on such a fake or hallucinated AI-generated material as precedents in support of the determination. We have no hesitation in declaring that such a decision is no decision in the eyes of the law, irrespective of whether such material had a direct or indirect bearing on the decision-making.”

Page 5 of the judgment

“So far as the responsibility of the bar is concerned, we direct the Bar Council of India, being the apex statutory body, to constitute a committee and deliberate on this issue of members of the bar submitting such fake and hallucinated material before the Court as if they are precedents of law.”

Page 6 of the judgment

“Judicial process and the judgment under challenge are tainted by the usage of materials which are said to be precedents, but in reality, they are unreal, fake, and do not exist at all. A decision of a Court or an adjudicating authority based on material which is fake and hallucinated is no decision at all, and it amounts to subversion of the rule of law. Such a decision is unsustainable and has to be set aside at the earliest”

Page 10 of the judgment

Case and bench

Parties: Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd.
Case: Civil Appeal No. 11950 of 2025
Decided: 2 July 2026
Bench: Pamidighantam Sri Narasimha, Alok Aradhe
Opinions: Unanimous judgment of the Court signed by Pamidighantam Sri Narasimha and Alok Aradhe, JJ.; the text does not name the author.

Questions on this case

4 questions in live Law Maker papers mention this case. A few from free papers:

Question 1, Legal Current Affairs: July 2026
Match the Supreme Court judgments of July 2026 (List I) with the Bench that delivered them (List II): List I A. Vanashakti v. Union of India B. Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd. C. Tejas J. Shah v. Mantri Technology Constellations Pvt. Ltd. D. Manjula Kapoor v. State of Himachal Pradesh List II 1. Vikram Nath and Sandeep Mehta, JJ. 2. Manoj Misra and Vijay Bishnoi, JJ. 3. Surya Kant, CJI, Joymalya Bagchi and Vipul M. Pancholi, JJ. 4. P.S. Narasimha and Alok Aradhe, JJ.
1. A. A-2, B-4, C-1, D-3
2. B. A-4, B-3, C-2, D-1
3. C. A-3, B-4, C-1, D-2
4. D. A-3, B-1, C-4, D-2
Show the answer
C. A-3, B-4, C-1, D-2
Vanashakti (2026 INSC 761) was decided by a three-Judge Bench presided over by the Chief Justice; Pooja Ramesh Singh (2026 INSC 668) by Narasimha and Aradhe, JJ.; Tejas J. Shah (2026 INSC 746) by Vikram Nath and Sandeep Mehta, JJ.; and Manjula Kapoor (2026 INSC 789) by Manoj Misra and Vijay Bishnoi, JJ.
Question 2, Legal Current Affairs: July 2026
With reference to Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd. (2 July 2026), consider the following statements: 1. The Court said that it is misconduct on the part of an advocate to cite AI-generated judgments without verification. 2. The Court directed the Bar Council of India to constitute a committee to prescribe a guiding principle against such citations and the disciplinary action that will follow a violation. 3. Having set aside the NCLT and NCLAT orders, the Court itself decided the Section 7 application under the Insolvency and Bankruptcy Code, 2016 on merits. Which of the statements given above is/are correct?
1. A. 2 and 3 only
2. B. 1 only
3. C. 1 and 2 only
4. D. 1, 2 and 3
Show the answer
C. 1 and 2 only
Paragraphs 7 and 9 of the judgment support statements 1 and 2. Statement 3 is wrong: the Court restored the Section 7 application to the NCLT, expressed no view on merits and asked the NCLT to decide it expeditiously.
Question 3, Legal Current Affairs: July 2026
In Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd., decided on 2 July 2026, the Supreme Court set aside orders of the NCLT and the NCLAT because the NCLT had relied on non-existent precedents generated through Artificial Intelligence. What did the Court declare about a decision that relies on such fake or hallucinated material?
1. A. It stands unless the party attacking it shows that the fake material directly changed the final result of the case
2. B. It is voidable at the option of the losing party, who must first seek a review before the same forum within thirty days
3. C. It is no decision in the eyes of law and must be set aside even if only an iota of such material entered the decision
4. D. It is valid if the presiding member files an affidavit disclosing the research tools used and the source of the citations
Show the answer
C. It is no decision in the eyes of law and must be set aside even if only an iota of such material entered the decision
The Bench of P.S. Narasimha and Alok Aradhe, JJ. (2026 INSC 668) declared zero tolerance for citing or relying on unverified AI-generated precedents: a decision resting on fake or hallucinated material is no decision in law, whether the material had a direct or indirect bearing, and must be set aside. No proof of effect on the outcome is required.

Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd.

Supreme Court of India, 2 July 2026, 2 judges, 2026 INSC 668

Facts

Questions before the Court

What is the legal status of a decision of a court or tribunal that relies on non-existent, fake or hallucinated AI-generated material as precedent?
Could the NCLT order admitting the Section 7 application and the NCLAT order affirming it stand when they rested on such material?

What the Court held

Courts must adopt zero tolerance for producing, citing or using AI-generated precedents without verification. A decision relying on fake or hallucinated AI-generated material as precedent is no decision in the eyes of the law, whether the material had a direct or indirect bearing, and must be set aside even if an iota of such material enters the decision-making.
It is misconduct for an advocate to cite such judgments without verification, and a serious lapse for a judge to rely on them. The judgment does not bear on the rightful use of AI, only on presenting or relying on fake material as if it were a court precedent.
The Bar Council of India was directed to constitute a committee, deliberate on members of the bar submitting fake and hallucinated material as precedents, and prescribe a guiding principle to prevent it along with the disciplinary action that will follow a violation.
As it was undisputed that the NCLT relied on non-existent judgments and AI-generated paragraphs wrongly attributed to real citations, the NCLT order of 28.08.2024 and NCLAT order of 11.09.2025 were set aside. The Section 7 application was restored, to be decided afresh on merits, preferably within two weeks, with status quo meanwhile.

Why it matters

In the Court's words

Copied from the official judgment; each passage links to its page.

“More than the inevitable consequence of setting aside such judgments, what is significant for our decision-making is our resolve to adopt AI technology in aid of adjudication, while at the same time asserting and declaring total and absolute control over adjudication, with a human in the loop at every stage.”

Page 1 of the judgment

“It is necessary for Courts to adopt a zero-tolerance mode for producing, citing or using AI-generated precedents without verification. It is a misconduct on the part of an advocate to cite such judgments without verification. Equally, it is a serious lapse if a judge relies on such a fake or hallucinated AI-generated material as precedents in support of the determination. We have no hesitation in declaring that such a decision is no decision in the eyes of the law, irrespective of whether such material had a direct or indirect bearing on the decision-making.”

Page 5 of the judgment

“So far as the responsibility of the bar is concerned, we direct the Bar Council of India, being the apex statutory body, to constitute a committee and deliberate on this issue of members of the bar submitting such fake and hallucinated material before the Court as if they are precedents of law.”

Page 6 of the judgment

“Judicial process and the judgment under challenge are tainted by the usage of materials which are said to be precedents, but in reality, they are unreal, fake, and do not exist at all. A decision of a Court or an adjudicating authority based on material which is fake and hallucinated is no decision at all, and it amounts to subversion of the rule of law. Such a decision is unsustainable and has to be set aside at the earliest”

Page 10 of the judgment

Case and bench

Parties: Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd.
Case: Civil Appeal No. 11950 of 2025
Decided: 2 July 2026
Bench: Pamidighantam Sri Narasimha, Alok Aradhe
Opinions: Unanimous judgment of the Court signed by Pamidighantam Sri Narasimha and Alok Aradhe, JJ.; the text does not name the author.

Questions on this case

4 questions in live Law Maker papers mention this case. A few from free papers:

Question 1, Legal Current Affairs: July 2026
Match the Supreme Court judgments of July 2026 (List I) with the Bench that delivered them (List II): List I A. Vanashakti v. Union of India B. Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd. C. Tejas J. Shah v. Mantri Technology Constellations Pvt. Ltd. D. Manjula Kapoor v. State of Himachal Pradesh List II 1. Vikram Nath and Sandeep Mehta, JJ. 2. Manoj Misra and Vijay Bishnoi, JJ. 3. Surya Kant, CJI, Joymalya Bagchi and Vipul M. Pancholi, JJ. 4. P.S. Narasimha and Alok Aradhe, JJ.
1. A. A-2, B-4, C-1, D-3
2. B. A-4, B-3, C-2, D-1
3. C. A-3, B-4, C-1, D-2
4. D. A-3, B-1, C-4, D-2
Show the answer
C. A-3, B-4, C-1, D-2
Vanashakti (2026 INSC 761) was decided by a three-Judge Bench presided over by the Chief Justice; Pooja Ramesh Singh (2026 INSC 668) by Narasimha and Aradhe, JJ.; Tejas J. Shah (2026 INSC 746) by Vikram Nath and Sandeep Mehta, JJ.; and Manjula Kapoor (2026 INSC 789) by Manoj Misra and Vijay Bishnoi, JJ.
Question 2, Legal Current Affairs: July 2026
With reference to Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd. (2 July 2026), consider the following statements: 1. The Court said that it is misconduct on the part of an advocate to cite AI-generated judgments without verification. 2. The Court directed the Bar Council of India to constitute a committee to prescribe a guiding principle against such citations and the disciplinary action that will follow a violation. 3. Having set aside the NCLT and NCLAT orders, the Court itself decided the Section 7 application under the Insolvency and Bankruptcy Code, 2016 on merits. Which of the statements given above is/are correct?
1. A. 2 and 3 only
2. B. 1 only
3. C. 1 and 2 only
4. D. 1, 2 and 3
Show the answer
C. 1 and 2 only
Paragraphs 7 and 9 of the judgment support statements 1 and 2. Statement 3 is wrong: the Court restored the Section 7 application to the NCLT, expressed no view on merits and asked the NCLT to decide it expeditiously.
Question 3, Legal Current Affairs: July 2026
In Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd., decided on 2 July 2026, the Supreme Court set aside orders of the NCLT and the NCLAT because the NCLT had relied on non-existent precedents generated through Artificial Intelligence. What did the Court declare about a decision that relies on such fake or hallucinated material?
1. A. It stands unless the party attacking it shows that the fake material directly changed the final result of the case
2. B. It is voidable at the option of the losing party, who must first seek a review before the same forum within thirty days
3. C. It is no decision in the eyes of law and must be set aside even if only an iota of such material entered the decision
4. D. It is valid if the presiding member files an affidavit disclosing the research tools used and the source of the citations
Show the answer
C. It is no decision in the eyes of law and must be set aside even if only an iota of such material entered the decision
The Bench of P.S. Narasimha and Alok Aradhe, JJ. (2026 INSC 668) declared zero tolerance for citing or relying on unverified AI-generated precedents: a decision resting on fake or hallucinated material is no decision in law, whether the material had a direct or indirect bearing, and must be set aside. No proof of effect on the outcome is required.