Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd.

What happened

Jammu and Kashmir Bank filed an application under Section 7 of India's Insolvency and Bankruptcy Code to begin insolvency proceedings against Essel Infraprojects Ltd. On August 28, 2024, the Mumbai bench of the National Company Law Tribunal (NCLT) admitted the application. On September 11, 2025, the National Company Law Appellate Tribunal (NCLAT) upheld that order.

The NCLT's order relied on 6 citations to Supreme Court decisions that could not be verified. Some were entirely non-existent, including ICICI Bank Ltd. v. Urban Infrastructure Real Estate Ltd., (2019) 16 SCC 528. Others were real decisions, such as Everest Kento Cylinders Ltd. v. Union of India and Canara Bank v. N.G. Subbaraya Setty, quoted for paragraphs they do not contain. The NCLAT repeated those references without checking them. The Supreme Court found that the bank's counsel had not cited these authorities. According to the judgment, the NCLT obtained them through its own research, and the Court described the NCLT as having "relied upon non-existent, fake and hallucinated material, generated through Artificial Intelligence (AI)."

What the court did

In a judgment in Pooja Ramesh Singh v. Jammu and Kashmir Bank Ltd., reported as 2026 INSC 668, the Court set aside both the NCLT and NCLAT orders and restored the application to the NCLT for a fresh decision. The Court stated that a decision resting on such material is "no decision in the eyes of the law," whether or not the fabricated authority affected the result. It called for "zero tolerance for the Bar as well as the Bench to cite, refer to, or rely on such material."

Where it stands

After the judgment in Pooja Ramesh Singh, the insolvency application is back before the NCLT, which must decide it afresh without reference to the 6 authorities. No report of the new decision was found as of September 2026. The Supreme Court did not decide whether the bank's application should ultimately be admitted.

The obligation it engaged

This matter differs from most in this record because no party supplied the false authority. The tribunal did. That makes it a direct instance of Clause 3 of the Expert Record Standard, independent authority, in the hands of a decision-maker. Precedents and paragraph references entered the order on a system's authority and were not checked against the law reports. The appellate tribunal's repetition of them engaged Clause 4 a second time. An error that was checkable was adopted by a second reviewer who could have checked it. The check that would have caught all 6 citations is the same one an expert should apply to any authority, whatever its source: open the report, find the paragraph, and read it before relying on it.

The Court's view that a tainted decision fails whether or not the false material changed the result has a parallel for experts. A report that rests in part on unverified output is exposed as a whole, and not only in the paragraph where the error sits.

Sources

• Indian Kanoon (judgment text) · July 2, 2026
  Pooja Ramesh Singh vs Jammu And Kashmir Bank Ltd on 2 July, 2026
• Verdictum · July 2026
  Zero-Tolerance For Using AI-Generated Precedents Without Verification: Supreme Court Sets Aside NCLT, NCLAT Orders Citing Fake Judgments
• Natural and Artificial Law · 2026
  Judicial AI Hallucinations or Errors: 11 Cases and Counting

What could not be confirmed

The judgment was reviewed through a summary of its text rather than read in full; the full list of directions (including any direction to the Bar Council of India, reported by one reading but not confirmed) and the time limit for the NCLT's fresh decision were not confirmed. The AI tool was not identified.