Bombay High Court Quashes Customs Order Over Alleged AI-Generated Fake Supreme Court Judgments
The Bombay High Court has set aside a Customs Department order against Quanta Logistics Pvt. Ltd. after concerns emerged that the adjudicating authority had relied upon two allegedly non-existent Supreme Court judgments, suspected to have been generated using Artificial Intelligence (AI).
A Division Bench comprising Justice M.S. Karnik and Justice Sandesh D. Patil passed the order on October 30, 2026, in Quanta Logistics Pvt. Ltd. v. Commissioner of Customs (Import-I), Writ Petition No. 5093 of 2026. The proceedings concerned an order dated August 11, 2026, issued by the Commissioner of Customs (Import-I), Mumbai.
Challenge to the Customs Department's Order
Quanta Logistics challenged the Customs Department's order, alleging that the adjudicating authority had relied on two Supreme Court judgments that could not be located in recognised legal databases or law reports.
Senior Advocate Venkatesh Dhond, appearing for the petitioner, questioned the authenticity of these judicial references and argued that they could be AI-generated hallucinations. The company had also written to the Customs Commissioner on September 1, 2026, requesting copies of the judgments. However, the requested documents were not provided.
The petitioner further raised concerns regarding the authority's independent application of mind while passing the impugned order.
Reliance on Supreme Court's Observations on AI-Generated Citations
During the proceedings, the petitioner relied upon the Supreme Court's decision in Vijay Ghanshyam Gadiya v. Union of India (2026), which addressed the dangers of relying on fabricated or unverified AI-generated legal materials in adjudicatory proceedings.
The Supreme Court emphasised that Artificial Intelligence may assist the adjudicatory process, but it cannot replace independent judicial reasoning. It also highlighted the need to verify legal precedents before relying upon them in judicial or administrative decisions.
Customs Department Agrees to Reconsider the Matter
During the hearing, Advocate Jitendra B. Mishra, representing the Customs Department and the Union of India, agreed that the challenged order could be set aside and the matter reconsidered afresh.
Consequently, the Bombay High Court quashed the Customs order dated August 11, 2026, by consent of the parties. The petitioner was directed to appear before the Customs Commissioner on November 5, 2026, at 11:00 AM.
The authority was directed to schedule a further hearing and complete the fresh proceedings within eight weeks from November 5, 2026. The writ petition was accordingly disposed of.
Why Does This Decision Matter?
The decision highlights the growing importance of accuracy and accountability in the use of Artificial Intelligence in legal and administrative processes. Although AI tools can assist in legal research and drafting, they may generate fabricated case names, incorrect citations or judicial decisions that do not exist.
For legal practitioners and adjudicating authorities, the development reinforces a fundamental responsibility: every legal precedent must be independently verified before it is cited or relied upon.
The ruling also serves as a reminder that technological assistance cannot replace the application of an independent mind in legal decision-making.
Source: Bombay High Court, Quanta Logistics Pvt. Ltd. v. Commissioner of Customs (Import-I), Writ Petition No. 5093 of 2026.