Gujarat High Court invalidates GST orders over reliance on AI-generated non-existent case law

The Gujarat High Court has nullified multiple GST rulings after revealing that a tax officer depended on fabricated AI-generated case law, underscoring the need for strict verification in AI-assisted legal processes.

The Gujarat High Court has annulled a series of GST proceedings against Faiz Enterprise after finding that a tax officer had relied on artificial intelligence-generated case law that did not exist or had no bearing on the dispute. In a judgment delivered on August 20, 2026, a bench of Justices A.S. Supehia and Vaibhavi D. Nanavati said the adjudication could not stand where the authority had not independently checked the legal material it used. According to the court, the officer’s reliance was so flawed that the order appeared to rest entirely on unverified AI output.

The case arose from a show-cause notice, a cancellation of GST registration, the rejection of a revocation request and an appellate order that together kept the cancellation in place. During the hearing, the petitioner pointed out that some of the authorities cited in the order did not exist, while others were inaccurately described or irrelevant to the issue. The court then examined the officer’s explanation and the department’s response before setting the orders aside and directing a fresh notice and a reasoned reconsideration of the taxpayer’s defence.

The officer, Devang Arvindkumar Yadav, submitted an unconditional apology and said the error stemmed from inexperience. He acknowledged using AI to help draft the order and locate the case law. The court also noted that he had attended an AI training programme on August 18, two days before the ruling.

The judgment has wider significance because the Gujarat State Tax Department issued instructions on August 18 governing the use of AI in quasi-judicial work. Those rules require officers to verify any case law, statutory provision, rule, circular or notification identified through AI against primary sources, check whether decisions remain good law, and record reasons when a taxpayer’s cited authority is rejected. The court said those directions must be followed strictly and warned that any breach would amount to contempt. The broader message from the ruling is clear: AI may assist legal drafting, but it cannot replace an officer’s own application of the law to the facts.

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