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Incident Tracker / India

Sammaan Capital Ltd v. Mantri Infrastructure Pvt Ltd, CRP No. 49 of 2025

·High Court of Karnataka, Bengaluru·INRegulatory referral

In India, the Karnataka High Court (24 March 2025) found that a Bengaluru City Civil Court judge had decided a jurisdiction question by relying on two Supreme Court judgments that were never delivered. Justice Devdas called the conduct disturbing and directed that the order be placed before the Chief Justice for action against the trial judge.

Court
High Court of Karnataka, Bengaluru
Date
2025-03-24
Who used the AI
Not recorded
AI tool
Not identified in the record
Conduct
A Bengaluru City Civil Court judge, rejecting a jurisdictional objection, based the order on two Supreme Court decisions that were never delivered by any court. On revision, the High Court found the citations fabricated and directed action against the trial judge. No AI tool is named in the order.
Outcome
Regulatory referral
Penalty
No monetary penalty recorded
Regulatory outcome
No separate regulatory disposition recorded
Status
Verified against listed sources
Last checked
Not separately recorded

What was fabricated or misused

  • M/s. Jalan Trading Co. Pvt. Ltd. v. Millenium Telecom Ltd., Civil Appeal No.5860/2010 — no such Supreme Court decision was rendered
  • M/s.Kvalrner Cemintation India Ltd. v. M/s.Achil Builders Pvt. Ltd., Civil Appeal No.6074/2018 — no such Supreme Court decision was rendered

What the court said

“However, the learned Senior Counsel submits that on careful search, it is found that no such decision is rendered by the Hon'ble Apex Court.”
High Court of Karnataka, Bengaluru, [5]
“What is more disturbing is the fact that the learned judge of City Civil Court has cited two decisions which were never decided by the Apex Court or any other Court.”
High Court of Karnataka, Bengaluru, [10]
“The learned Senior Counsel appearing for the plaintiffs has clearly stated that such decisions were not cited by the learned counsel for the plaintiffs.”
High Court of Karnataka, Bengaluru, [10]
“Copy of this order shall be placed before Hon'ble the Chief Justice, for further action against the learned judge.”
High Court of Karnataka, Bengaluru, [12]

Timeline

  1. Defendant No. 1 invoked the pledge agreement and issued a sale notice.
  2. The plaintiffs withdrew their commercial suit as not pressed.
  3. The City Civil Court rejected the defendants' Order VII Rule 10 application.
  4. The civil revision petition was heard and reserved.
  5. The High Court allowed the revision petition and directed action.
  6. The parties were directed to appear before the City Civil Court.

Why this case matters

Sammaan Capital is different from lawyer-filed hallucination cases such as Mavundla v MEC and Harber v HMRC. The questioned authorities appeared in a trial judge's own order, and counsel for the party that benefited from the order said they had not cited them. The High Court did not identify any AI tool, so the record matters as a judicial-use warning rather than a confirmed chatbot incident. It also shows why the tracker records fabricated legal authority even when the source of fabrication remains unresolved.

Practice note

A court order should cite only authorities that can be found in an official database or recognised reporter. If a judge relies on a case not cited by either side, the citation and holding still need independent verification before the order is issued. Lawyers reviewing an adverse order should check unfamiliar authorities promptly and raise the issue with the appellate court using the exact citation that cannot be found.

Primary sources for this incident

Related regulation records for this incident

No related regulation record has been linked to this incident yet.

Similar incidents on the record

Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Sammaan Capital Ltd v. Mantri Infrastructure Pvt Ltd, CRP No. 49 of 2025”, safelegalai.com/tracker/sammaan-capital-v-mantri (accessed 2026-09-16). Data: CC BY 4.0.

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