The Bombay High Court has drawn a clear line against the careless use of AI in legal submissions, penalizing a litigant ₹50,000 for filing arguments that leaned on a completely fabricated judgment.
Justice MM Sathaye condemned the practice of “dumping” machine-generated content, emphasizing that unverified AI output can obstruct justice rather than aid it.
The submissions, filed by Mohammed Yasin, director of Heart & Soul Entertainment, cited a case titled Jyoti w/o Dinesh Tulsiani vs Elegant Associates—a judgment the Court and its clerks could not locate. Observers noted telltale signs of AI use, including repetitive phrasing and unusual tick-mark formatting, pointing to reliance on tools like ChatGPT.
Justice Sathaye made it clear that AI can assist legal research, but ultimate responsibility rests with the filer. “Even an advocate using such tools must verify that every reference is genuine, relevant, and exists,” the judge stated.
The Court also criticized Yasin for submitting the documents after a cursory signature, without checking their accuracy. “This dumping of irrelevant or non-existent material must be stopped at the outset,” Justice Sathaye said, warning that such conduct could attract costs and, for advocates, potential Bar Council scrutiny.
The dispute arose from a leave-and-licence agreement over a flat in a MHADA complex at Oshiwara, Mumbai, involving film producer Deepak Shivkumar Bahry and Heart & Soul Entertainment.
The Court dismissed Yasin’s request for perjury and contempt proceedings but directed him to pay ₹50,000 to the High Court Employees Medical Fund within two weeks. The judge noted that repeated adjournments and reliance on fake citations justified the cost imposition as a deterrent.
Yasin appeared in person, while the petitioner was represented by advocates Janay Jain and Rishabh Jadhav of Parinam Law Associates.
