Bombay High Court Pulls Litigant For 'Dumping' On It Unverified, AI-Generated Submissions, Imposes ₹50K Costs
The Bombay High Court last week imposed a cost of Rs 50,000 on a litigant for submitting a 'non-existing' judgment generated through Artificial Intelligence (AI) which the court and its clerks could not find and thus deprecated such practice of 'dumping' non-existing and irrelevant materials on the court.
Single-judge Justice Milind Sathaye was seized with a dispute between two film producers owing to a flat at Mumbai's Oshiwara area, which was governed by the provisions of the Maharashtra Rent Control Act, 1999.
The judge took exception to the respondent, a film producer - Mohammed Yasin, who appeared as party-in-person and tendered some written submissions in February and April 2025. Among these submissions, Yasin had included 'Jyoti w/o Dinesh Tusiani vs Elegant Associates'— a case on which he relied upon.
However, the judge and his clerks were 'at pains' to search for the copy of this judgment as it was not available anywhere, even on the internet. The judge noted that the submissions bore 'give-away features' such as green-box tick-marks, bullet-point marks, repetitive submissions etc.,
"This Court strongly feels that the submissions are prepared using an AI tool such as Chat GPT or alike. A strong pointer is seen from a reference made to one alleged caselaw “Jyoti w/o Dinesh Tulsiani Vs. Elegant Associates”. Neither citation is given nor a copy of judgment is supplied by the Respondent. This Court and its law clerks were at pains to find out this caselaw but could not find. This has resulted in waste of precious judicial time," Justice Sathaye said in the judgment pronounced on January 7.
The judge underscored that it is good if parties, lawyers use AI tools for their research but cautioned that it should be used with 'great responsibility.'
"If an AI tool is used in aid of research, it is welcome; however, there is great responsibility upon the party, even an advocate using such tools, to cross verify the references and make sure that the material generated by the machine/computer is really relevant, genuine and in existence," the judge said.
The judge noted that Yasin has simply filed written submissions by signing them without verifying its contents and deprecated such a practice.
"This practice of dumping documents / submissions on the Court and making the Court go through irrelevant or non-existing material must be deprecated and nipped at bud. This is not assistance to the Court. This is a hurdle in swift delivery of justice. This Court will not take such practices kindly and it is going to result in costs. If an advocate is found to be indulging in such practice, then even stricter action of referring to Bar Council may follow," the judge made it clear.
Justice Sathaye therefore, imposed costs of Rs 50,000 on Yasin.
"Respondent is directed to pay costs of Rs. 50,000/- to High Court Employees Medical Fund, within a period of 2 weeks from today and submit the proof of payment in the Registry," the judge ordered.
On merits also, the judge did not found 'substance' in Yasin's contentions and therefore, ordered him to forthwith vacate the suit flat and hand over its possession to the Petitioner.
Appearance:
Advocates Janay Jain and Rishabh Jadhav instructed by Parinam Law Associates appeared for the Petitioner.
Mohammed Yasin appeared as party-in-person.
Case Title: Deepak Shivkumar Bahry vs Heart & Soul Entertainment Ltd. (Writ Petition 8390 of 2009)