Supreme Court Sets Aside ₹425 Crore Penalty on Diamond Trader Over AI Hallucinated Citations

A Penalty Built on Sand

In a landmark ruling that underscores the sanctity of judicial integrity, the Supreme Court of India set aside a staggering ₹425.28 crore customs penalty imposed on diamond trader Vijay Ghanshyam Gadiya . The penalty was quashed after the Court discovered that the adjudicating officer had relied on non-existent judgments and fake citations generated by artificial intelligence—a phenomenon the Court branded a "hallucination of AI."

The AI Hallucination Problem

The dispute originated from an Order-in-Original dated October 8, 2025 , passed by the Additional Commissioner of Customs, Surat. The officer imposed the penalty under Section 114 of the Customs Act, 1962 , alleging that Gadiya misdeclared a consignment of natural diamonds as lab-grown diamonds to avail a lower tariff. Gadiya challenged the order before the Gujarat High Court, which dismissed his appeal on January 20, 2026 , prompting him to approach the Supreme Court.

Before the apex court, Gadiya's counsel contended that several judgments and articles cited in the Order-in-Original were generated using AI. The Court decided to independently verify these citations. What it found was alarming: some case laws cited were entirely non-existent or carried fake citations, while others—though real—did not lay down the legal propositions attributed to them. The Court concluded that these errors appeared to be the product of AI hallucination.

Zero Tolerance for Fake Citations

The Bench of Justices Dipankar Datta and Sheel Nagu referred to its earlier decision in Pooja Ramesh Singh v. Jammu & Kashmir Bank Ltd. (2026 SCC OnLine SC 1258), which established a zero-tolerance policy for using unverified AI-generated precedents. That decision held that reliance on such material violates the sanctity of adjudication and constitutes misconduct for both advocates and judges.

Reiterating this principle, the Court observed that even an iota of fake or hallucinated material entering the decision-making process renders the order unsustainable.

A Cautionary Note on AI

While acknowledging the potential of AI as an assistive tool, the Court drew a clear line. “Assistance can never be substituted for adjudication. AI may well serve as training wheels but entrusting it with the pilot’s seat would be both imprudent and dangerous,” the Bench remarked. The Court noted that it had recently released draft Regulations for Use of Artificial Intelligence in Courts, 2026 , but stressed that AI cannot replace human judgment.

Fresh Adjudication Ordered

The Supreme Court set aside both the Gujarat High Court's order and the penalty order. It revived the proceedings against Gadiya and directed fresh adjudication by an officer of the same rank other than the one who passed the original order. The Court also left it to the appointing authority to consider initiating appropriate action against the officer, in accordance with law.

The ruling serves as a stark reminder that while technology can assist, it must never compromise the integrity of the judicial process.