The Gujarat High Court flagged a “worrying trend” of quasi-judicial orders relying on AI-generated, dubious case law. In proceedings involving Marhaba Overseas Pvt. Ltd., it found GST order citations untraceable or wrongly attributed to different courts, raising serious concerns.
GUJARAT: A week after the Supreme Court warned lawyers against using artificial intelligence (AI) to draft petitions, the Gujarat High Court has raised alarm about a “worrying trend” quasi-judicial orders that appear to rely on AI-generated and dubious case law.
In proceedings involving Marhaba Overseas Pvt. Ltd., the court found several judgments cited in a GST order could not be located, and some were wrongly attributed to different courts.
The Supreme Court matter had likewise involved non-existent judgments being cited as precedents in AI-assisted petitions. That backdrop prompted the High Court to consider “prescribing some parameters” for quasi-judicial bodies when they rely on judicial precedents in their orders.
The dispute arose from action taken against Marhaba Overseas Pvt. Ltd. The company received a notice dated June 29, 2025, on the GST portal from the Additional Commissioner of Central Goods and Services Tax and Central Excise.
After the company filed its defence, the commissioner issued an order on September 26, 2025. Marhaba challenged that order in the High Court through senior advocate Saurabh Soparkar and advocate Parth Bhatt.
They argued that several judgments relied on by the Additional Commissioner could not be located despite searches, and that some rulings were misattributed shown as Gujarat High Court decisions when they were actually from the Supreme Court or other courts.
The lawyers asked the High Court that
“some guidelines are required to be prescribed to the quasi-judicial authorities in referring to the judgments blindly generated through AI, which are not in existence and, even if they are in existence, they do not remotely apply to the issues raised by the assessee”.
The bench of Justice A.S. Supehia and Justice Pranav Trivedi agreed the submission “merits acceptance”, calling the situation “a worrying trend”.
The court observed,
“The reasonings/findings recorded by the respondent commissioner, while dealing with the defence submissions, by placing reliance on the aforementioned judgment/citations, are flawed and deceptive. It appears that the commissioner, without reading the actual judgments, followed the AI-generated citations and case law.”
The High Court added,
“We find that this is an appropriate case, wherein some directions are called for regulating/prescribing some parameters for quasi-judicial authorities while placing reliance on the judgments either of the high courts or of the Supreme Court of India, while dealing with legal issues raised by an assessee.”
A further hearing was scheduled for March 13, with GST counsel directed to address the issue.
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