HC Warns Authorities Against Blind Reliance on AI-Generated Judgments

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  • Last Updated on 5 March, 2026

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AI-generated judgments

Case Details: Marhabba Overseas (P.) Ltd. vs. Union of India - [2026] 183 taxmann.com 743 (Gujarat)

Judiciary and Counsel Details

  • A.S. Supehia & Pranav Trivedi, JJ.
  • S N Soparkar, Sr. Adv., Parth H Bhatt, Ms Khyati A Chugh & Sudeep Biswas for the Petitioner.
  • Ankit Shah & Pradip D Bhate for the Respondent.

Facts of the Case

The petitioner challenged the show cause notice (SCN) and the impugned order issued by the Commissioner. During the hearing, the petitioner submitted that the Commissioner had rejected four core defences cited, which were either non-existent or unrelated to the issues raised in the defence statement. It was contended that the reasoning and findings recorded by the Commissioner were flawed and deceptive, as they appeared to be based on AI-generated citations without reading the actual judgments. It sought that guidelines be prescribed for quasi-judicial authorities to prevent reliance on non-existent or irrelevant AI-generated judgements. The matter was accordingly placed before the High Court.

High Court Held

The High Court held that the reliance placed by the Commissioner on the aforementioned judgements was incorrect, as the cited authorities were either non-existent. It was observed that the findings recorded by the Commissioner under Section 75 of the CGST Act, and the Gujarat GST Act, were flawed due to unverified reliance on AI-generated case law. It was held that quasi-judicial authorities must ensure that the judgements and citations they refer to are factually accurate, directly applicable, and verified before incorporation in orders. The Court directed that appropriate guidelines be prescribed to prevent reliance on AI-generated or irrelevant judgement.

List of Cases Referred to

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Author: Taxmann

Taxmann Publications has a dedicated in-house Research & Editorial Team. This team consists of a team of Chartered Accountants, Company Secretaries, and Lawyers. This team works under the guidance and supervision of editor-in-chief Mr Rakesh Bhargava.

The Research and Editorial Team is responsible for developing reliable and accurate content for the readers. The team follows the six-sigma approach to achieve the benchmark of zero error in its publications and research platforms. The team ensures that the following publication guidelines are thoroughly followed while developing the content:

  • The statutory material is obtained only from the authorized and reliable sources
  • All the latest developments in the judicial and legislative fields are covered
  • Prepare the analytical write-ups on current, controversial, and important issues to help the readers to understand the concept and its implications
  • Every content published by Taxmann is complete, accurate and lucid
  • All evidence-based statements are supported with proper reference to Section, Circular No., Notification No. or citations
  • The golden rules of grammar, style and consistency are thoroughly followed
  • Font and size that's easy to read and remain consistent across all imprint and digital publications are applied