Delhi HC Allows Withdrawal of Plea Citing Non-Existent Judgments and AI-Generated Content

In what appears to be one of the first instances of alleged “AI hallucination” before the Delhi High Court, a petition was dismissed as withdrawn after it was revealed that the plea relied on fabricated case law and non-existent judicial precedents.

The petition had been filed by the Greenopolis Welfare Association (GWA) before a single-judge bench of Justice Girish Kathpalia. GWA was challenging orders of the trial court that restricted it from filing its written statement while allowing pleas by various homebuyers.

However, during the proceedings, the respondents, homebuyers represented by senior advocates N. Hariharan, Abhijat, and Sanjay Ghose, produced a compilation alleging that the GWA’s petition cited false and fabricated case law.

Among the references questioned was Chitra Narain v. DDA, 2000 (87) DLT 276, which the respondents pointed out does not exist. The petition also cited paragraphs 73 and 74 of Raj Narain v. Indira Nehru Gandhi, (1972) 3 SCC 850, despite the judgment containing only 27 paragraphs.

Confronted with these discrepancies, senior counsel appearing for the petitioner sought permission to withdraw the plea. 

Allowing the withdrawal, the Court said, "Petitioner has assailed orders dated 18.09.2025, 20.09.2025 and 22.09.2025 of the learned trial court. However, after addressing partly, learned senior counsel for petitioner on instructions seeks permission to withdraw this petition."

Highlighting the non-existent citations, the Court added," All learned senior counsel and counsel appearing for respondents submit that they would take appropriate steps since some of the judicial precedents cited on behalf of petitioner do not even exist and in some of the precedents, the quoted portions do not exist. At the request of both sides, it is made clear that submissions advanced today were confined only to the impugned orders and nothing else.”

Accordingly, the present petition and the accompanying applications were dismissed as withdrawn.

For Petitioners:Mr. Rakesh Tiku, Sr. Advocate with Mr. Gaurav Kohli and Mr. Ashish, Advocates.

For Respondents: Mr. N. Hariharan, Sr. Advocate with Mr. Ajay Sabharwal, Mr. Prateek Bhalla, Ms. Punya Rekha Angara, Mr.Aman Akhtar, Ms. Vasundhara N., Ms. Sana Singh, Ms. Vasundhara Raj Tyagi, Mr. Arjan Singh Mandla and Ms. Gauri Ramachandran, Advocates for R-1 to 15. Mr. N. Hariharan and Mr. Abhijat, Sr. Advocates with Mr. Ajay Sabharwal and Mr. Jai Sikand, Advocates for R1 (plaintiffs no. 1 to 4). Mr. Sanjoy, Sr. Advocate with Mr. Ajay Sabharwal, Mr. Jai Sikand and Mr. Anuj Aggarwal, Advocates for R1 (plaintiffs no. 5 to 19). Mr. Neeraj Dev Gaur, Advocate for R-1 (plaintiffs no. 20 & 21). Mr. Tushar Sannu and Ms. Shaoni Das, Advocates for R-21 & 22.

Case Title: GREENOPOLIS WELFARE ASSOCIATION (GWA) vs NARENDER SINGH AND ORS

Bench: Justice Girish Kathpalia

Hearing Date: 25 September 2025