SRINAGAR: In a judgment carrying significant implications for the growing use of artificial intelligence in the legal system, the High Court of Jammu and Kashmir and Ladakh has cautioned judicial officers against relying on AI-generated legal material without independent verification, after discovering that a trial court order had cited judgments that were either incorrectly referenced or could not be traced at all.
The observations came from Justice Wasim Sadiq Nargal while dismissing a petition filed by the management of Woodland House School, Srinagar, against execution of an interim order directing payment of salary dues to a former employee.
While upholding the trial court’s order on merits, the High Court expressed concern over the manner in which judicial precedents had been cited in the impugned order and used the occasion to issue a broader warning about the increasing reliance on artificial intelligence tools in legal and judicial work.
The court said an independent verification undertaken during the hearing revealed that citations attributed to two key judgments relied upon by the trial court were incorrect. In one instance, the title of the judgment itself could not be traced despite diligent searches. In another, although a judgment bearing a similar title existed, the citation mentioned in the order was found to be entirely inaccurate.
Justice Nargal observed that reliance on judicial precedents forms an essential component of judicial decision-making and that authorities cited in support of legal conclusions must be accurate, authentic and capable of verification. The court noted that the practice of paraphrasing perceived legal principles instead of reproducing the actual ratio of judgments also carried risks of distortion.
In what is believed to be one of the strongest judicial warnings in the region on the subject, the court specifically addressed the growing use of artificial intelligence-based research tools. While acknowledging their utility, the judge made it clear that such technologies cannot replace judicial scrutiny.
“Any proposition of law, citation, extract, or precedent generated or suggested by an artificial intelligence tool must be independently verified from authentic and authoritative sources before being relied upon in a judicial order,” the court held.
The judgment stressed that the ultimate responsibility for the accuracy and authenticity of every judicial order rests with the presiding judge and not with any technological platform used during research.
To prevent similar lapses, the court issued a series of directions applicable to judicial officers across the Union Territory. It directed that every citation, precedent, factual assertion or legal proposition obtained through AI platforms or similar technologies must be independently verified before incorporation into judicial orders. It further directed that judgments relied upon must carry complete and accurate citations and that, wherever possible, relevant extracts should be reproduced verbatim rather than paraphrased. Citations sourced from unofficial databases or secondary compilations must also be cross-checked with authoritative sources.
The court ordered that a copy of the judgment be circulated among all judicial officers in Jammu and Kashmir and Ladakh through the Registrars Judicial of both wings of the High Court.
The observations came in proceedings arising from a long-running dispute between Woodland House School and former employee Shakeel Ahmad Malik. Malik had filed a civil suit claiming entitlement to the post of supervisor and seeking the release of salary. During the pendency of the suit, the trial court directed the school to pay him 50 per cent of his salary for a specified period, subject to an undertaking to refund the amount if he ultimately lost the case.
The school challenged the interim order before the appellate court and later before the High Court, but both challenges failed. When the employee initiated proceedings to secure implementation of the order, the school again approached the High Court, arguing that an interim injunction could not be executed through execution proceedings and that the only remedy available was under Order 39 Rule 2-A of the Civil Procedure Code.
Rejecting the contention, Justice Nargal relied on Supreme Court precedent to hold that interim orders are capable of execution under Section 36 of the Code of Civil Procedure and cannot be reduced to mere paper directions. The court observed that judicial orders must have practical effect and that parties cannot indefinitely avoid compliance through repeated litigation.
The judgment also took a dim view of the conduct of the petitioners, observing that they had repeatedly sought to delay implementation of orders that had already been upheld by multiple judicial forums. Describing the litigation as lacking bona fides and intended primarily to obstruct compliance, the court dismissed the petition and imposed costs of Rs 25,000 on the school management.
Upholding the order of the 4th Additional Munsiff, Srinagar, the High Court directed the petitioners to comply with the salary payment order and left it open to the executing court to adopt all permissible legal measures to secure enforcement.
The case, Principal, Woodland House School and Others v. Shakeel Ahmad Malik, was decided on June 6, 2026. The matter was argued for the petitioners by Senior Advocate Anil Bhan, assisted by advocates Danish Majeed Dar and Moneesa Manzoor.
Legal observers say the judgment may become a significant reference point in future discussions on the use of artificial intelligence in courts, particularly as judges and lawyers increasingly employ AI-powered research tools. The ruling underscores that while technology may assist legal research, responsibility for the accuracy of judicial reasoning remains entirely human.
