In a significant ruling on the responsible use of Artificial Intelligence in courts, the Andhra Pradesh High Court has clarified that an order does not become invalid merely because it cites non-existent judgments generated through AI tools-so long as the legal reasoning itself is sound. The ruling came while dismissing a civil revision petition challenging a trial court’s refusal to strike down an advocate commissioner’s report.
Justice Ravi Nath Tilhari delivered the judgment, underlining the growing judicial concern over unchecked reliance on AI-generated legal material.
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Background of the Case
The case arose from a civil suit filed for permanent injunction relating to a property dispute in Vijayawada. During the trial, an Advocate Commissioner was appointed to inspect the property and submit a report.
Earlier, the trial court had appointed the commissioner following directions of the High Court. After the report was submitted, the defendants filed an application seeking to strike it down, alleging:
- The commissioner acted beyond the court’s directions
- The inspection was conducted without a surveyor
- The report was prepared in collusion with the plaintiffs
The trial court rejected these allegations and accepted the commissioner’s report as part of the record.
Aggrieved, the defendants approached the High Court under Article 227 of the Constitution, arguing that the trial court had relied on judicial precedents that did not exist.
Court’s Observations
Justice Ravi Nath Tilhari examined the issue in detail and noted that the trial court had indeed cited certain judgments that were later found to be non-existent. A report submitted by the trial judge confirmed that those citations were generated using an AI tool and were mistakenly assumed to be genuine.
The High Court, however, made an important distinction.
“The mere reference to non-existent citations does not invalidate an order, if the legal principles applied are otherwise correct,” the court observed.
The judge clarified that the real test was not the source of the citation but whether the reasoning and application of law were legally sound.
On Use of Artificial Intelligence in Courts
The judgment contains a detailed caution on the growing use of AI tools in legal research.
Justice Tilhari observed that while AI can assist in organizing information, it cannot replace judicial reasoning or legal verification.
“The use of Artificial Intelligence without verification can mislead courts and compromise the integrity of judicial proceedings,” the bench noted.
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The court referred to recent decisions from Indian and foreign courts where fake or misleading AI-generated citations had caused serious concern. It emphasized that judges and lawyers must verify every authority before relying on it.
On the merits of the case, the court held:
- A commissioner’s report is only a piece of evidence
- It does not decide rights of parties
- It can be tested during trial through objections and cross-examination
- Mere allegations of bias or collusion are not sufficient to discard it
“The commissioner’s report only aids the court. It neither binds the court nor replaces judicial evaluation,” the judge stated.
Since the trial court had correctly applied settled legal principles, the High Court found no reason to interfere.
Final Decision
Dismissing the Civil Revision Petition, the High Court held:
- Use of AI-generated citations, though careless, did not vitiate the order
- The legal reasoning adopted by the trial court was correct
- No jurisdictional or legal error was found
- The petitioners are free to challenge the report during trial
“The order does not suffer from any illegality warranting interference under Article 227,” the court concluded.
The revision petition was accordingly dismissed, with no order as to costs.
Case Title: Gummadi Usha Rani & Anr. v. Sure Mallikarjuna Rao & Anr.
Case Number: Civil Revision Petition No. 2487 of 2025
Decision Date: January 2026
