What did the Supreme Court hold about AI-generated citations in 2026?

In Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd. (2026 INSC 668), decided on 2 July 2026, a Bench of Justice P.S. Narasimha and Justice Alok Aradhe set aside orders of the National Company Law Tribunal and the National Company Law Appellate Tribunal to the extent they relied on fabricated, AI-generated precedents that did not exist as cited. The Court directed courts and tribunals to adopt a zero-tolerance approach to the production, citation or use of AI-generated precedents without verification. The judgment does not ban AI research tools; it makes independent verification of every authority a non-negotiable obligation.

Are the Regulations for Use of Artificial Intelligence in Courts, 2026 binding law?

No, and this is the single most common error aspirants make on this topic. The Regulations for Use of Artificial Intelligence (AI) in Courts, 2026 were released by the Supreme Court of India on 3 June 2026 as a draft framework, with public feedback invited until 20 June 2026 at office.regcc@sci.nic.in. A draft circulated for consultation is not a source of enforceable obligation. Until the framework is finalised and notified, references to Draft Regulation 43(3) disclosure or the proposed Apex Body must be described as proposals, not as operative rules governing filings.

Why is the 36-hour figure in deepfake takedown orders significant?

Rule 3(1)(d) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 requires an intermediary, on receiving actual knowledge through a court order or a government notification, to remove or disable access to unlawful information within thirty-six hours. On 4 August 2026, in Saleem Iqbal Shervani v. Meta Platforms and Others, CS(OS) 676/2026, the High Court of Delhi fixed exactly that period. Compliance matters because Section 79(3)(b) of the Information Technology Act, 2000 withdraws safe-harbour immunity where an intermediary fails to act expeditiously after acquiring actual knowledge.

How does the hallucinated-citation problem connect to the Advocates Act, 1961?

An advocate owes the court a duty of candour, and the Advocates Act, 1961 supplies the disciplinary architecture for breaches of professional standards. Section 35 of the Advocates Act, 1961 empowers a State Bar Council to refer a case of alleged professional or other misconduct to its disciplinary committee, and Section 38 provides an appeal to the Supreme Court of India. Placing a fabricated authority before a court is capable of engaging that framework. Note carefully that the 2026 rulings covered in this digest concerned tribunal and trial-court orders and did not themselves impose disciplinary sanctions on counsel.

What are the highest-probability facts from this topic for the 2026-27 exam cycle?

Six items. First, the citation 2026 INSC 668 and the date 2 July 2026 for the zero-tolerance ruling. Second, the earlier order of 5 May 2026 in the same matter. Third, that the AI Regulations for Courts, 2026 are a draft released on 3 June 2026 with feedback until 20 June 2026. Fourth, that the draft AI Committee was chaired by Justice P.S. Narasimha. Fifth, the 36-hour window under Rule 3(1)(d) and the 24-hour window under Rule 3(2)(b) of the IT Rules, 2021. Sixth, the Delhi High Court order of 30 April 2026 staying a decree of Rs 1.08 crore in the Akasa Air appeal.

Artificial Intelligence in Indian Courts 2026 — Hallucinated Citations, Draft Rules and Professional Duty (Aspirant Digest)

Artificial intelligence became a subject of binding judicial direction in India during 2026. On 2 July 2026 the Supreme Court of India, in Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd. (2026 INSC 668), set aside tribunal orders that rested on non-existent AI-generated precedents and directed courts and tribunals to adopt a zero-tolerance approach to unverified AI-generated case law. That is the operative holding to memorise.

Why this topic scores 14 out of 15. It combines a fresh Supreme Court citation, a live consultation document, two High Court orders with hard numbers, and a Chief Justice's address — spanning Administrative Law, the Legal Profession paper, Technology Law and Constitutional Law simultaneously. Very few 2026 developments feed four papers at once.

One warning before you memorise anything. Part of the 2026 material is a judgment; part is a draft under consultation. Setters build negative-marking questions on exactly that distinction. Keep the two columns separate in your notes.

Theme 1 — The Zero-Tolerance Ruling on Hallucinated Citations

A hallucinated citation is a judgment reference — case name, court and year — that reads as authoritative but does not exist in the cited form. The term is borrowed from hallucination in large language models, where a system generates plausible but fabricated output.

The procedural history

The matter arose from insolvency proceedings. In 2019, Jammu and Kashmir Bank Limited extended a credit facility of ₹200 crore to Pan India Utilities Distribution Company Limited. Essel Infraprojects Limited furnished a corporate guarantee, secured additionally by a mortgage over land at Gorai, Borivali, Mumbai. On default, ₹87.43 crore was alleged outstanding. The bank applied under Section 7 of the Insolvency and Bankruptcy Code, 2016 (IBC), treating the corporate guarantor as a financial debtor. The NCLT Mumbai Bench admitted the application on 28 August 2024; the NCLAT affirmed on 11 September 2025.

Before the Supreme Court, the suspended director alleged that the NCLT order cited judgments untraceable in any official database. On 5 May 2026, a Bench of Justice P.S. Narasimha and Justice Alok Aradhe permitted the appellant to place those citations on record by affidavit within one week, recording that the issue struck at the very integrity of judicial proceedings itself. No stay of the resolution process was granted then.

The holding of 2 July 2026

The same Bench delivered judgment on 2 July 2026, cited as 2026 INSC 668 in Civil Appeal No. 11950 of 2025. Three propositions to carry into the hall:

Orders set aside. The NCLT and NCLAT orders were set aside to the extent they relied on fabricated precedents that did not exist as cited.
Zero tolerance. Courts and tribunals must adopt a zero-tolerance approach to producing, citing or using AI-generated precedents without verification.
Integrity of proceedings. An order whose legal authority rests on non-existent citations has a structurally compromised reasoning foundation.

The discriminator. The judgment does not prohibit AI-assisted legal research. It prohibits reliance without verification. An MCQ option reading "the Supreme Court banned AI tools in courts" is wrong.

Theme 2 — The Draft AI Regulations: Consultation, Not Law

On 3 June 2026 the Supreme Court of India released a draft framework titled Regulations for Use of Artificial Intelligence (AI) in Courts, 2026, prepared by an AI Committee chaired by Justice P.S. Narasimha, and invited public feedback until 20 June 2026 at office.regcc@sci.nic.in.

State this as a draft in every answer you write. As at the date of this digest, no record of the framework having been finalised or notified was traced. Whether it has since been adopted, amended or dropped is an open question, and you should say so rather than assert commencement.

The draft, as circulated, proposed the following architecture.

Proposed prohibitions

AI systems may not decide cases, pass sentences, assess facts or render judicial decisions of any kind. Risk-scoring models predicting bail outcomes, flight risk, recidivism or witness credibility are barred, as is behavioural profiling of accused persons, witnesses or litigants. Opaque or non-explainable systems may not be used in matters affecting legal rights or personal liberty.

Proposed permitted uses

Case management and cause-list preparation; transcription and translation subject to human verification; legal research including case-law retrieval and citation checking; litigant-facing procedural chatbots under human supervision; and accessibility tools such as text-to-speech and Braille conversion.

Proposed disclosure duty and governance

Draft Regulation 43(3) would require any party or legal representative using AI to prepare pleadings, documents or evidence to declare that fact at the time of filing. Draft Regulation 43(6) would place full responsibility for fabricated or inaccurate content on the person submitting it — the automated origin being no defence. The draft further proposed a permanent Apex Body at the Supreme Court, AI Committees and AI Secretariats in the Supreme Court and each High Court, a Centre of Research and Excellence on Artificial Intelligence (CoRE-AI), annual technical, legal and ethical audits, court-maintained AI Registers, and compliance with the Digital Personal Data Protection Act, 2023 (DPDP Act).

The Mains hook. The draft is rule-making by the Court in its administrative capacity, not adjudication — a clean illustration for a question on the judicial-versus-administrative function distinction.

Theme 3 — Trial-Court Drafting: The Akasa Air Appeal

On 30 April 2026 a Division Bench of the High Court of Delhi comprising Justice Pratibha M. Singh and Justice Madhu Jain stayed a decree of ₹1.08 crore passed by the Saket District Commercial Court against Akasa Air (SNV Aviation Pvt. Ltd.) in Akasa Air v. ABS Tours and Travels. The appeal lay under Section 13 of the Commercial Courts Act, 2015.

Two independent grounds:

Concerns about AI-generated drafting. The Bench recorded a prima facie impression that portions of the trial judgment were AI-generated — references to non-existent statutory provisions, and attribution of propositions to Supreme Court precedents that those precedents do not contain. It expressly returned no conclusive finding at the stay stage, observing that attributing non-existent propositions to judicial precedents would be a matter of serious concern.
Flawed damages computation. The trial court treated the entire ticket value of 640 cancelled tickets as profit, without deducting procurement cost. Loss of profit must be computed on net margin, not gross revenue — settled under the Indian Contract Act, 1872.

The stay was granted on Akasa Air depositing ₹20 lakh with the Registrar General by 30 May 2026; the matter was listed for 20 August 2026.

Note the doctrinal separation. The damages ground stands on its own. The AI ground was flagged, not decided. Never write that the Delhi High Court held the judgment to be AI-generated.

Theme 4 — Synthetic Media: Deepfakes and Intermediary Liability

Delhi High Court, 4 August 2026

In Saleem Iqbal Shervani v. Meta Platforms and Others, CS(OS) 676/2026, Justice Tushar Rao Gedela directed Meta to remove two allegedly AI-generated videos from Facebook and Instagram within 36 hours, and restrained the creator and the republisher from publishing them until further orders. The videos, published 13 July 2026, artificially generated the plaintiff's face, voice and dialogue.

The 36-hour figure is not judicial choice. Rule 3(1)(d) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 requires removal within thirty-six hours of actual knowledge through a court order or government notification. Section 79 of the Information Technology Act, 2000 (IT Act) grants intermediaries exemption from liability for third-party content, but Section 79(3)(b) withdraws it where the intermediary fails to act expeditiously after actual knowledge. Compare Rule 3(2)(b): twenty-four hours to act on a complaint concerning impersonation, including artificially morphed images.

Bombay High Court, 5 August 2026

In Nitin Jairam Gadkari v. Meta Platforms and Others, Interim Application (L) No. 25165 of 2026, Justice Arif Doctor ordered takedown of AI-manipulated content, granted a dynamic injunction covering future material notified by the plaintiff without a fresh application, and directed disclosure of basic subscriber information of anonymous uploaders. At least 24 links were identified; damages of ₹11 crore were claimed. Relief was granted under Order XXXIX Rules 1 and 2 of the Code of Civil Procedure, 1908. The regulatory backdrop had tightened earlier that year: the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Amendment Rules, 2026, notified 10 February 2026 by G.S.R. 120(E) and effective 20 February 2026, introduced obligations around synthetically generated information.

Theme 5 — Professional Duty: The Advocate's Side of the Problem

On 23 July 2026, Chief Justice of India Surya Kant, addressing newly qualified Advocates-on-Record (AoRs), cautioned that social-media popularity is not professional credibility and warned against overreliance on artificial intelligence in legal drafting. An AoR is qualified under the Supreme Court Rules, 2013 to file and act before the Supreme Court and is answerable for what is placed on its record. The remarks are guidance to the profession, not an amendment to those Rules.

Three framework provisions to attach in a descriptive answer — settled background, not provisions applied in the 2026 rulings above:

Advocates Act, 1961 — Section 35 empowers a State Bar Council to refer alleged professional or other misconduct to its disciplinary committee; Section 38 provides an appeal to the Supreme Court; the Bar Council of India frames standards of professional conduct under Section 49(1)(c).
Duty of candour — an advocate is an officer of the court and may not knowingly mislead it as to fact or law. Placing a fabricated authority before a court is the paradigm breach.
Contempt of Courts Act, 1971 — Section 2(c) defines criminal contempt to include acts interfering with the due course of any judicial proceeding. No source consulted records contempt proceedings arising from the 2026 AI-citation matters; this is the doctrinal category a question may invite, not an outcome.

Research Gaps — Stated Honestly

Whether the Regulations for Use of Artificial Intelligence (AI) in Courts, 2026 have been finalised, notified or brought into force after the 20 June 2026 consultation window was not verified. Treat the framework as a draft.
The outcome of the 20 August 2026 hearing in the Akasa Air appeal was not traced.
Whether any disciplinary or contempt proceedings followed the hallucinated-citation findings was not traced. Do not assert that any advocate or judicial officer was penalised.

Key Facts to Remember

#	Date	Development	Key Fact	Subject
1	28 Aug 2024	NCLT Mumbai admits Section 7 IBC application	Default of ₹87.43 crore; ₹200 crore facility	Insolvency Law
2	11 Sep 2025	NCLAT affirms admission	Appeal dismissed	Insolvency Law
3	5 May 2026	Supreme Court procedural order	Affidavit permitted; integrity of proceedings flagged	Administrative Law
4	30 Apr 2026	Delhi HC stays Akasa Air decree	₹1.08 crore; 640 tickets; ₹20 lakh deposit	Contract / Commercial
5	3 Jun 2026	Draft AI Regulations for Courts, 2026	Feedback until 20 June 2026; Committee chaired by Justice P.S. Narasimha	Administrative Law
6	2 Jul 2026	2026 INSC 668	Zero tolerance for unverified AI citations; tribunal orders set aside	Administrative Law
7	23 Jul 2026	CJI address to new AoRs	Credibility over visibility; caution on AI drafting	Legal Profession
8	4 Aug 2026	Delhi HC deepfake takedown	36 hours under Rule 3(1)(d), IT Rules 2021	Technology Law
9	5 Aug 2026	Bombay HC dynamic injunction	24 links; ₹11 crore claimed; subscriber data ordered	Technology Law
10	20 Feb 2026	IT Amendment Rules, 2026 effective	Notified 10 Feb 2026 by G.S.R. 120(E)	Technology Law

Exam Angle

MCQ format: "In which case did the Supreme Court of India direct a zero-tolerance approach to AI-generated precedents?" — Answer: Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd., 2026 INSC 668, decided 2 July 2026.
MCQ format: "Under Rule 3(1)(d) of the IT Rules, 2021, within what period must an intermediary remove unlawful information after actual knowledge?" — Answer: thirty-six hours. Trap option: twenty-four hours, which is Rule 3(2)(b) and is triggered by a complaint about impersonation, not a court order.
MCQ format: "Which provision withdraws intermediary safe harbour on failure to act after actual knowledge?" — Answer: Section 79(3)(b), Information Technology Act, 2000.
Descriptive format: "An unverified citation is not merely an error; it goes to the integrity of the proceeding. Examine, with reference to the Supreme Court's 2026 ruling on AI-generated precedents and the advocate's duty of candour." (Judiciary Mains, UPSC Law Optional)
Descriptive format: "Discuss the constitutional and administrative-law objections to permitting AI-based risk assessment in bail adjudication." (Judiciary Mains)
Key facts to memorise: 2026 INSC 668, dated 2 July 2026; earlier order 5 May 2026; draft AI Regulations released 3 June 2026, feedback to 20 June 2026; 36 hours versus 24 hours; ₹1.08 crore decree stayed 30 April 2026 on a ₹20 lakh deposit.
Related provisions: Section 7, IBC 2016; Section 13, Commercial Courts Act, 2015; Sections 79 and 79(3)(b), IT Act 2000; Rules 3(1)(d), 3(2)(b) and 4(2), IT Rules 2021; Order XXXIX Rules 1 and 2, CPC 1908; Sections 35, 38 and 49(1)(c), Advocates Act, 1961; Section 2(c), Contempt of Courts Act, 1971; DPDP Act, 2023.

Exam-wise Relevance

For CLAT / AILET aspirants

Legal-GK recall: the citation 2026 INSC 668, the 36-hour deepfake window, and the fact that the AI Regulations for Courts remain a draft. Comprehension passages on AI regulation are near-certain in the 2026-27 cycle, and the safe-harbour chain — Section 79, then Section 79(3)(b), then Rule 3(1)(d) — is the reasoning ladder most will test.

For judiciary exam aspirants

Prelims: dates, the citation, the two takedown windows, the bench (Justices P.S. Narasimha and Alok Aradhe). Mains: the duty of candour under the Advocates Act, 1961; the difference between flagging a concern prima facie (Delhi High Court, 30 April 2026) and returning a finding; and the appellate consequence when an order rests on non-existent authority.

For UPSC Law Optional and GS-II

GS-II: judicial reform and technology in governance — pair the draft Apex Body, CoRE-AI and AI Registers with the DPDP Act, 2023 compliance requirement. Law Optional: administrative rule-making and consultation, plus intermediary liability under the IT Act, 2000.

Frequently Asked Questions

Did the Supreme Court ban artificial intelligence in Indian courts in 2026?

No. The judgment of 2 July 2026 in 2026 INSC 668 directs zero tolerance for producing, citing or relying on AI-generated precedents without verification. It does not prohibit AI-assisted legal research, transcription or case management. The obligation created is one of independent verification of every authority relied upon, not abstinence from the technology.

Are the AI Regulations for Courts, 2026 in force?

They were released on 3 June 2026 as a draft for public consultation, with feedback invited until 20 June 2026. Whether the framework has since been finalised or notified was not verified for this digest. Describe it as a draft, and describe Regulation 43(3) disclosure and the Apex Body as proposals.

What is the difference between the 24-hour and 36-hour takedown timelines?

Rule 3(2)(b) of the IT Rules, 2021 gives an intermediary twenty-four hours to act on a complaint concerning impersonation, including artificially morphed images. Rule 3(1)(d) gives thirty-six hours to remove information after actual knowledge through a court order or government notification. The first is triggered by a user; the second by a legal instrument.

Can a tribunal order be set aside only because it cited non-existent judgments?

The Supreme Court set aside the NCLT and NCLAT orders to the extent they relied on fabricated precedents. The reasoning is that an order whose authority rests on non-existent citations is structurally compromised. Whether every citation defect independently vitiates an order, or must be assessed cumulatively with the substantive reasoning, is a question you should present as open rather than settled.

What is a dynamic injunction?

A dynamic injunction extends a takedown order to material not yet identified, so that when the plaintiff notifies the platform of further infringing content, the platform must act without a fresh court application. The Bombay High Court granted such relief on 5 August 2026 in Interim Application (L) No. 25165 of 2026, while giving platforms liberty to approach the Court where an item falls in a grey area.

source_notes: This digest is synthesised entirely from Veritect's own previously published daily-news articles and the Tier 1 primary records they cite; no external portal narrative was used. The citation 2026 INSC 668, Civil Appeal No. 11950 of 2025, the date 2 July 2026, the bench of Justice P.S. Narasimha and Justice Alok Aradhe and the zero-tolerance direction come from legal-news-output/2026/July/01-to-02/2026-07-02-supreme-court-zero-tolerance-ai-hallucinated-precedents-nclt-nclat.md, whose primary source is the Supreme Court judgment on sci.gov.in. The procedural order of 5 May 2026, the ₹200 crore facility, the ₹87.43 crore default, the NCLT Mumbai admission of 28 August 2024 and the NCLAT affirmation of 11 September 2025 come from legal-news-output/2026/May/18-to-19/2026-05-19-supreme-court-nclt-hallucinated-ai-citations-essel-infraprojects-integrity.md, sourced to the Supreme Court order of that date. The draft AI framework details, the 3 June 2026 release date, the 20 June 2026 feedback deadline, the AI Committee chair, Draft Regulations 43(3) and 43(6) and the governance architecture come from legal-news-output/2026/June/03-to-04/2026-06-03-supreme-court-draft-ai-regulations-courts-india.md, sourced to the Supreme Court's latest-updates notice. The Akasa Air facts are reconciled across two on-disk articles that both record the order date as 30 April 2026 — legal-news-output/2026/April/30/2026-04-30-delhi-hc-stays-akasa-air-decree-flags-ai-trial-judgment.md and legal-news-output/2026/May/09/2026-05-09-delhi-hc-flags-ai-use-trial-court-judgment-akasa-air.md; the ₹20 lakh deposit condition, the 30 May 2026 deposit deadline and the Section 13 Commercial Courts Act, 2015 route appear only in the later of the two, and the 20 August 2026 listing appears in both. The deepfake material comes from legal-news-output/2026/August/04-to-05/2026-08-04-delhi-high-court-meta-36-hour-takedown-ai-deepfake-videos-shervani.md and legal-news-output/2026/August/04-to-05/2026-08-05-bombay-high-court-deepfake-takedown-gadkari-meta-google-x-subscriber-data.md; both record that the respective court portals returned HTTP errors and that the signed orders could not be resolved to stable deep links, so the matters are identified by case number, judge and order date, and the source links point to each Court's own site. The Chief Justice's remarks of 23 July 2026 come from legal-news-output/2026/July/23-to-24/2026-07-23-cji-surya-kant-advocates-on-record-caution-ai-drafting-credibility.md. The Advocates Act, 1961 and Contempt of Courts Act, 1971 provisions are settled statutory background supplied by this digest for examination framing; no source consulted records disciplinary or contempt proceedings arising from the 2026 AI-citation matters, and none is asserted.

This digest is prepared for legal-examination preparation. It is not legal advice.