Safiya Malik

The High Court of Judicature at Bombay Single Bench of Justice Milind Sathaye last week imposed costs of Rs 50,000 on a litigant after noting that its written submissions cited an AI-generated, untraceable judgment which the Court and its law clerks could not locate, along with other irrelevant material placed on record. The Court was dealing with a dispute between two film producers arising from a leave-and-licence arrangement for a flat near Oshiwara Police Station, Mumbai, governed by the Maharashtra Rent Control Act, 1999. Allowing the petition, the Bench set aside the revisional order, restored the competent authority’s eviction direction, and ordered the licensee to hand over possession, making the eviction executable forthwith.

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The petition was filed under Article 227 challenging a revisional order passed under Section 44 of the Maharashtra Rent Control Act, 1999, which had set aside an eviction order of the Competent Authority under Section 24. The dispute concerned a flat near Oshiwara Police Station, Mumbai, involving two film producers, with the petitioner described as the owner-licensor and the respondent as the licensee.

The petitioner stated that the respondent was inducted under a registered leave-and-licence agreement dated 05.01.2007 for 22 months for residential use, that the respondent breached the terms, and that the agreement was terminated by notice dated 04.05.2008. It was recorded that the respondent did not vacate and had filed a civil suit alleging that the petitioner agreed to transfer the flat, which the petitioner denied.

Before the Competent Authority, the respondent relied on contentions including asserted commercial use, electricity-related material, and a contract dated 20.02.2006 to claim a lien/charge for recovery. The petitioner led oral evidence; the respondent filed a pursis stating he did not wish to lead oral evidence.

The record noted that the respondent, Mohammed Yasin, appeared party-in-person and filed written submissions in February 2025 and April 2025. Among them, he referred to an alleged case law “Jyoti w/o Dinesh Tulsiani Vs. Elegant Associates” without providing a citation or a copy.

On the written submissions, the Court stated: "The Respondent has filed written submissions in February 2025 and April 2025." "From the overall tenor of the written submissions and a few give-away features, such as green-box tick-marks, bullet-point-marks, repetitive submissions etc., this Court strongly feels that the submissions are prepared using an AI tool such as Chat GPT or alike."

The Court recorded: "A strong pointer is seen from a reference made to one alleged caselaw “Jyoti w/o Dinesh Tulsiani Vs. Elegant Associates”." "Neither citation is given nor a copy of judgment is supplied by the Respondent." "This Court and its law clerks were at pains to find out this caselaw but could not find."

The Court stated: "This has resulted in waste of precious judicial time." "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." "This Court finds that the Respondent has simply filed written submissions by signing them without verifying its contents."

The Court recorded: "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." "This is not assistance to the Court." "This is a hurdle in swift delivery of justice."

On consequences, the Court stated: "This Court will not take such practices kindly and it is going to result in costs." "If an advocate is found to be indulging in such practice, then even stricter action of referring to Bar Council may follow."

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The Court directed that “the impugned order dated 02.09.2009 in Revision Application No.132 of 2009 is set aside” and “Revision Application No.132 of 2009 stands dismissed”. The order of eviction passed by the Competent Authority in Case No.38 of 2008 dated 15.04.2009 is confirmed” and that “Rule is made absolute in the above terms. Interim Application No.6969 of 2025 is dismissed. The Respondent is directed to hand over possession of the suit flat to the Petitioner” and clarified that “the eviction order becomes executable forthwith.”

“The Respondent shall pay costs of Rs.50,000/- to the High Court Employees Medical Fund within a period of two weeks from today” and “proof of payment shall be submitted in the Registry.”

Advocates Representing the Parties

For the Petitioner: Mr. Janay Jain, Advocate, along with Mr. Rishabh Jadhav, instructed by Parinam Law Associates

For the Respondent: Mr. Mohammed Yasin, Director of the Respondent Company, Party-in-Person

Case Title: Deepak s/o Shivkumar Bahry v. Heart & Soul Entertainment Ltd.
Neutral Citation: 2026: BHC-AS:828
Case Number: Writ Petition No. 8390 of 2009
Bench: Justice M.M. Sathaye