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Bombay High Court imposes ₹50,000 costs on litigant for unverified AI-generated submissions

The submissions cited a case titled Jyoti w/o Dinesh Tulsiani vs Elegant Associates, which the Court and its law clerks were unable to trace.

Neha Joshi

The Bombay High Court recently deprecated the practice of submitting unverified, AI-generated legal arguments, imposing costs of ₹50,000 on a litigant who relied on a non-existent judgment in his written submissions.

Justice MM Sathaye admonished the respondent for “dumping” machine-generated content on the court, holding that such conduct obstructs the swift delivery of justice.

Justice MM Sathaye

The Court noted that the written submissions filed by Mohammed Yasin, director of Heart & Soul Entertainment, bore “give-away” features typical of AI tools such as ChatGPT, including distinctive tick-marks and repetitive phrasing.

The submissions cited a case titled Jyoti w/o Dinesh Tulsiani vs Elegant Associates, which the Court and its law clerks were unable to trace.

“If an AI tool is used in aid of research, it is welcome; however, there is great responsibility upon the party, even an advocate using such tools, to cross verify the references and make sure that the material generated by the machine/computer is really relevant, genuine and in existence,” Justice Sathaye observed.

The Court was particularly critical of the fact that Yasin had filed the written submissions after merely signing them, without verifying their contents.

“This practice of dumping documents/submissions on the Court and making the Court go through irrelevant or non-existing material must be deprecated and nipped at bud,” the judge said.

The Court cautioned that such conduct would attract costs and, in the case of advocates, could even invite reference to the Bar Council.

The dispute arose from a leave and licence arrangement over a flat in a MHADA complex at Oshiwara, Mumbai, owned by film producer Deepak Shivkumar Bahry and used by Heart & Soul Entertainment Ltd, represented by Yasin.

The Court also dismissed the company’s application seeking perjury and contempt action and directed payment of ₹50,000 as costs to the High Court Employees Medical Fund within two weeks.

Justice Sathaye held that the respondent’s conduct, including repeated adjournments and reliance on fake citations, warranted the imposition of costs to deter such practices at the threshold.

​Advocates Janay Jain and Rishabh Jadhav, briefed by Parinam Law Associates, appeared for the petitioner.

Yasin appeared in person.

[Read order]

Deepak so Shivkumar Bahry v. Heart & Soul Entertainment.pdf
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