Analysis
SCO.LR | 2026 | Volume 7 | Issue 2
In this issue, we shortlist five judgements from 6 July to 10 July

Volume 7 Issue 2 of the Supreme Court Observer Law Reports (SCO.LR) is here!
We bring you five judgements delivered by the Supreme Court in the final week of its Partial Court Working Days, covering:
- Reliance on AI-generated fake precedents
- Autonomy and self-regulation for lawyers
- Adopted son-in-law’s inheritance rights
- Reporting child sexual assault
- Judicial interference with experts’ discretion
As always, SCO.LR issues come with well formatted judgements with linking and citation features alongside assistive mindmaps for easy research. Click here to access the entire database of SCO.LR judgements.
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The Supreme Court Observer Law Reports
SCO.LR | Volume 7 | Issue 2
6 July – 10 July 2026
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Reliance on AI-generated fake precedents
Pooja Ramesh Singh v Jammu and Kashmir Bank
2 July 2026
Citations: 2026 INSC 668 | 2026 SCO.LR 7(2)[6]
Bench: Justices P. S. Narasimha and Alok Aradhe
The Supreme Court held that a judicial decision relying, even partly, on fake, non-existent or AI-hallucinated precedents must be set aside. The Court adopted a zero-tolerance standard for the bar and the bench against citing unverified material, while permitting responsible, human-controlled AI assistance.
Jammu and Kashmir Bank initiated insolvency proceedings under Section 7 of the Insolvency and Bankruptcy Code, 2016 against Essel Infraprojects over defaulted credit facilities secured by a corporate guarantee. The National Company Law Tribunal (NCLT) admitted the application, appointed an Interim Resolution Professional and declared a moratorium under Section 14. The appellant,a suspended director of the corporate debtor, appealed on the ground that a demerger and subsequent amalgamation transferred the liabilities and extinguished the guarantee. The National Company Law Appellate Tribunal (NCLAT) dismissed the appeal. Subsequently, the appellant moved the Supreme Court, where it emerged that the NCLT had relied on non-existent authorities and fabricated passages had been falsely attributed to genuine citations.
The Supreme Court set aside the NCLT and NCLAT judgements and restored the Section 7 application for fresh adjudication on merits. It directed the NCLT to dispose of the application expeditiously,and ordered the parties to maintain status quo in the interim. The Court directed the Bar Council of India to constitute a committee to formulate disciplinary guidelines for advocates submitting fake or hallucinated legal precedents.
Keywords/phrases: Artificial Intelligence—AI hallucinations—Fake and non-existent precedents—Fabricated passages attributed to genuine citations—Mandatory verification of authorities—Human control over AI-assisted adjudication—NCLT and NCLAT judgements set aside—Section 7 application restored—Bar Council of India directed to frame guidelines.
Read the Judgement here.
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Autonomy and Self-regulation for Lawyers
Ajay Vijh v Indian Banks Association
7 July 2026
Citations: 2026 INSC 670 | 2026 SCO.LR 7(2)[7]
Bench: Justices P.S. Narasimha and Alok Aradhe
The Supreme Court held that the Indian Banks’ Association’s (IBA) Caution List is confined to fraud and cannot be used to address cases of professional negligence by advocates, which falls within the exclusive disciplinary jurisdiction of Bar Councils under the Advocates Act, 1961.
In 2018, Canara Bank panel advocate, Ajay Vijh, was blacklisted for professional negligence, alleging that a 2015 title opinion rendered by him for a ₹2 crore loan overlooked prior sale deeds. The bank reported him to the IBA, which placed him on the Caution List under “Third Party Entities Involved in Fraud”. The Allahabad High Court dismissed Vijh’s writ petition on maintainability, holding the IBA does not constitute “State” under Article 12.
The Supreme Court held that while the writ petition is maintainable under Article 226, relevant material implying professional negligence by an advocate must be taken to the State Bar Council for necessary action. It directed the Bar Council of India to audit its disciplinary mechanism and consider establishing a National Legal Academy.
Keywords/phrases: Advocates Act 1961—Panel advocate’s legal opinion—Removal from bank panel—IBA Caution List—Writ petition under Article 226—Exclusive disciplinary jurisdiction of Bar Councils—Caution List entry set aside—Audit of Bar Council of India’s disciplinary mechanism ordered—Recommended setting up of National Legal Academy.
Read the Judgement here.
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Adopted Son-in-Law’s Inheritance Rights
9 July 2026
Citations: 2026 INSC 672 | 2026 SCO.LR 7 (2)[8]
Bench: Justices Sanjay Karol and N.K. Singh
The Supreme Court held that an uncle-in-law cannot validly adopt a niece’s husband as ghardamad (son-in-law) within Oraon customary law. It ruled that custom must be clearly proved, courts cannot infer rights from silence, and the nearest male agnate succeeds to the property.
Sukhu Oraon had three sons: Dhungru, Ledura, and Bhoula. The plaintiff, Dhungru’s son also named Sukhu, claimed sole entitlement to all ancestral land. Bhoula’s daughter Budhain and husband Punai resisted the claim, asserting that childless Ledura had adopted Punai as a ghardamad, relying on a partition deed dated 27 February 1975. Trial courts dismissed the Plaintiff’s suit citing ethnographer S.C. Roy’s account of Oraon customs. The respondents moved the Patna High Court, which upheld the Trial Court’s judgement. Aggrieved, the petition moved the Supreme Court in a civil appeal.
The Supreme Court set aside the concurrent findings, holding that Roy’s ethnographic authority confined ghardamad status to adoptions by the last male owner or his widow, meaning Ledura, lacked authority to adopt Punai. The plaintiff, as the nearest male agnate, was held entitled to inherit the property.
Keywords/phrases: Sukhu Oraon’s three sons Dhungru, Ledura and Bhoula—Ledura, childless, adopts Bhoula’s son-in-law Punai as ghardamad—Bhoula’s daughter Budhain and Ledura execute partition deed dated 27 February 1975—Lower courts, citing ethnographer S.C. Roy, uphold Punai’s ghardamad status—Supreme Court holds Roy’s own account confines ghardamad adoption to last male owner or widow—Ledura, an uncle-in-law, lacks authority to adopt—Nearest male agnate entitled to inherit property.
Read the Judgement here.
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Reporting Child Sexual Assault
9 July 2026
Citations: 2026 INSC 675 | 2026 SCO.LR 7(2)[9]
Bench: Manoj Misra and K.V. Viswanathan
The Supreme Court held that Section 19(1) of the Protection of Children from Sexual Offences Act, 2012 (POCSO Act) requires any person with ’knowledge’ of an offence to report it. Such knowledge includes credible information received directly from a child victim.
The victim, an eight year old girl, allegedly told her elder sister that a senior student had sexually assaulted her at school. The sister informed the Head Girl, who informed Linda Sema, the Headmistress. Linda Sema conducted a personal physical examination of the victim, concluded there were no signs of assault, and chose not to report the matter. The petitioner, mother of the victim, learned of the incident five months later and filed an FIR. Police chargesheeted several staff for failing to report. However, the Trial Court discharged them for the lack of prima facie case being made out, which the Gauhati High Court affirmed. Aggrieved, the petitioner moved the Supreme Court.
The Supreme Court held that Linda Sema, who had received direct information from the victim, possessed ‘knowledge’ under Section 19(1) and was wrongly discharged. It restored proceedings against her under Section 21 of the POCSO Act and Section 176 of the Indian Penal Code, 1860 (IPC), but upheld the discharge of staff who had no direct information from the victim.
Keywords/phrases: AAA’s eight-year-old daughter allegedly sexually assaulted by senior student at school—Sister informs Head Girl, who informs Linda Sema, the school’s alleged Headmistress—Linda Sema personally verifies complaint instead of reporting—mother learns of incident, lodges FIR five months later—Trial Court discharges chargesheeted staff for want of prima facie case, High Court affirms—Supreme Court holds Linda Sema had ‘knowledge’ under Section 19(1) POCSO Act—discharge of staff without direct knowledge upheld.
Read the Judgement here.
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Expert Assessment of Suitability for Promotion
Director General, Council of Scientific and Industrial Research v Anil Earnest
10 July 2026
Citations: 2026 INSC 677 | 2026 SCO.LR 7(2)[10]
Bench: Justices Manoj Misra and Manmohan
The Supreme Court has held that suitability for promotion must be left to the determination of domain experts and, in absence of rules, a degree of latitude must be provided to them. Domain experts retain discretion to determine whether a scientist is ‘fit for promotion’.
Paragraph 3(b) of a 2011 Circular issued by the Council of Scientific and Industrial Research (CSIR) mandated evaluating candidates based on his Annual Performance Report/Performance Mapping Scheme along with Work Report scores for the period for promotion. The Assessment Committee denied a promotion to Dr Anil Earnest, a scientist at CSIR-National Aerospace Laboratories, Bangalore, who was awarded three per cent less than the 85 per cent screening threshold. Therefore, it did not recommend him for promotion. The Central Administrative Tribunal (CAT) and the Karnataka High Court held that the committee should have adopted the process of averaging of APRs/PMS marks and marks obtained on the Work Report and considered him eligible for promotion.
The Supreme Court set aside the CAT and High Court decisions, and dismissed Earnest’s application. It found that Paragraph 3(b) did not permit averaging of marks. It ruled that Paragraph 3(b) did not permit score-averaging, and because there were no allegations of malafides or challenges to the circular’s validity, the judiciary must respect the expert committee’s autonomy to score parameters independently.
Keywords/phrases: CSIR-NAL Bangalore scientist—Promotion to Senior Scientist from 19 September 2012—Annual appraisal marks averaged 92.1%, crossing 85% screening threshold—Assessment Committee scored Work Report at 82%, below threshold—Declined promotion—Earnest sought averaging of appraisal and Work Report scores to reach 87%—Central Administrative Tribunal accepted averaging principle—Allowed his application—High Court of Karnataka affirmed CAT’s reasoning -remanded it to committee—Supreme Court held Committee retained discretion—Dismissed application.
Read the Judgement here.