The Allahabad High Court on Monday dismissed a Public Interest Litigation (PIL) plea challenging the levy of 18% Goods and Services Tax (GST) on online legal research and legal educational data based services.

The Court questioned as to why the advocate who filed the plea in 2026 had suddenly become aware of the alleged unreasonableness of the tax when the tax rates were in force since 2017.

"The petitioner, an Advocate, has nowhere in the petition even indicated as to what suddenly has been the cause for the petitioner to become aware of the rate being higher despite the fact that the rate continues to exist since the year 2017," a bench of Chief Justice Arun Bhansali and Justice Kshitij Shailendra observed.

The PIL plea, filed by advocate Aniket Gupta, challenged the classification of online legal-research and legal-educational databases under Service Accounting Code (SAC) 998431, which attracts GST at an aggregate rate of 18%.

The PIL plea sought a distinct classification and a nil or concessional rate for these services. It was argued that the existing rate of 18% was arbitrary and the same was adversely affecting access to justice.

In his petition, Gupta submitted that online legal-research databases such as SCC Online, Manupatra and LexisNexis, along with legal-news services such as LiveLaw and Bar & Bench, were taxed at 18% under the same broad classification as online audio and video content and online games.

He argued that reliable access to statutes, notifications, subordinate legislation and judicial decisions was essential for competent legal advice, effective advocacy and the preparation of court pleadings.

The petition termed these online databases as "indispensable working tools of contemporary legal research", which individual advocates and small chambers could not practicably assemble themselves.

It further argued that the tax burden fell disproportionately on junior advocates and small practitioners, especially those who could not claim input tax credit.

The petitioner contended that for lawyers, it is necessary to have the said online tools available for the purpose of checking the veracity of the judgment to be cited in their petitioner.

It was argued that in case the lawyer cites a judgment, which is overruled and/or is a fake judgment, the same amounts to professional misconduct on the part of the lawyer.

The petition also relied on the Supreme Court's recent observations concerning fabricated or AI-generated legal citations.

It referred to the Supreme Court's recent decisions in Pooja Ramesh Singh vs. Jammu and Kashmir Bank Ltd. and Vijay Ghanshyam Gadiya vs. Union of India, to argued that advocates needed reliable legal-research databases to verify judgments and ensure that citations generated or identified through artificial intelligence were authentic.

The petitioner argued that imposing 18% GST on these tools, while expecting advocates to verify every legal authority cited before courts, placed an additional burden on the profession.

The PIL challenged the relevant central, Uttar Pradesh and integrated tax notifications insofar as they subjected online legal-research and legal-educational database services to GST at an aggregate rate of 18%.

The petitioner argued that printed books, law reports, newspapers and periodicals received more favorable tax treatment, but electronic law reports and legal databases were taxed at a higher rate despite serving a comparable knowledge-dissemination function.

The petition alleged that the classification was arbitrary and discriminatory, violating Articles 14 and 21 of the Constitution, read with Articles 38 and 39A.

The PIL plea also sought a direction to the Union government, the Central Board of Indirect Taxes and Customs, and the GST Council to reconsider the classification and rate, as well as the possibility of assigning the services a distinct classification and a nil or concessional rate.

Alternatively, the petitioner sought a direction to place the grievance before the GST Council and its Fitment Committee for consideration.

However, the High Court dismissed the PIL by observing thus:

"The petitioner was enrolled in the year 2020 and claims to continue practising for last six years and, therefore, the sudden awareness about the tax being unreasonable and filing of the PIL at the instance of the said petitioner, cannot be countenance".