This Weekly Legal Updates covers nine major developments across India’s legal landscape: the Supreme Court’s zero-tolerance stance on AI-generated fake precedents, new guidelines on using ITRs for motor accident compensation, menstrual hygiene as a constitutional right, passive euthanasia principles refined, and a stray dog crackdown. High Courts weighed in on AI misuse of celebrity personas, habeas corpus limits, and live-in relationship protections. The Law Ministry also unveiled its ‘Sankalp Patra’ reform roadmap — essential reading for judiciary aspirants and legal professionals tracking Article 21 jurisprudence.

Part I: Supreme Court Watch

1. Supreme Court Sets Aside NCLT and NCLAT Orders for Relying on AI-Generated Fake Precedents

Bench: Justices Pamidighantam Sri Narasimha and Alok Aradhe

Fact – The case arose out of insolvency proceedings that Jammu and Kashmir Bank Ltd. initiated against Essel Infraprojects Ltd. (EIL), the corporate guarantor of Pan India Utilities Distribution Company Ltd., after the latter defaulted on loan repayments. The NCLT admitted the bank’s Section 7 application under the Insolvency and Bankruptcy Code, 2016, appointed an Interim Resolution Professional, and imposed a moratorium — an order the NCLAT later affirmed. Before the Supreme Court, EIL’s suspended director argued that a corporate restructuring within the Essel Group had already discharged the guarantee. But the real story turned out to be procedural, not substantive.

Held: Both the NCLT and NCLAT had relied on judicial precedents that simply did not exist — AI-generated hallucinations cited in support of their conclusions. The Supreme Court held that this fundamentally vitiated the adjudicatory process, rendering both orders legally unsustainable. It adopted what it called a “zero-tolerance” approach: even minimal reliance on unverified AI-generated authorities undermines the integrity of judicial decision-making.

Key takeaway: The Court did not ban AI as a research tool — it made clear that AI-generated outputs must always be independently verified before being relied on in judicial proceedings. It also placed the verification burden squarely on both the Bar and the Bench, noting that courts cannot reasonably be expected to independently check every citation an advocate places before them, which is why lawyers carry a corresponding duty of authenticity. The Court has directed the Bar Council of India to constitute a committee to frame AI-usage guidelines for legal practice and recommend disciplinary measures for advocates who cite fabricated authorities.

Disposal: The NCLT and NCLAT orders were set aside; the Section 7 application was restored to the NCLT for fresh adjudication, to be decided within two weeks, with parties directed to maintain status quo. The Court expressed no opinion on the merits of the underlying insolvency dispute.

2. Supreme Court Lays Down Guidelines on Using Income Tax Returns to Compute Motor Accident Compensation

Case: Rashmirekha Tripathy v. Sriram General Insurance Co. Ltd., 2026 SCC OnLine SC 1256 Bench: Justices Sanjay Karol and Nongmeikapam Kotiswar Singh

Background: A 39-year-old construction contractor died in a road accident in Odisha. The Motor Accident Claims Tribunal (MACT) computed his income using only his latest Income Tax Return (ITR) and awarded compensation exceeding ₹2.27 crore. The Orissa High Court reduced this by averaging two years of ITRs instead. The claimants appealed, arguing the High Court’s approach was arbitrary and ignored the nature of the deceased’s business.

The core legal question: Should compensation under the Motor Vehicles Act, 1988 be based on the latest ITR, or an average of several years’ returns? High Courts and MACTs across the country had been answering this differently, prompting the Supreme Court to appoint amici curiae to help evolve a uniform standard.

The Court’s framework: ITRs are statutory documents and the most reliable evidence of income, but they cannot be applied mechanically — the real objective under Section 168 of the Act is “just and fair compensation,” reflecting actual earning capacity rather than pure arithmetic. The Court then drew a crucial distinction:

  • Salaried employees: the ITR of the immediately preceding assessment year should ordinarily govern, since it best captures recent promotions or salary revisions. Where a promotion occurred shortly before the accident and hasn’t yet reflected in a filed ITR, courts may rely on promotion letters and salary slips instead.
  • Self-employed persons and business owners: since income here fluctuates with business cycles and market conditions, the average of the previous three years’ ITRs should ordinarily be the reference point — though tribunals must still weigh factors like business location, growth trajectory, and capital-intensive investments.

The Bench also cautioned against blindly accepting ITRs filed after the accident or death, given the risk of inflated post-facto declarations — such returns need independent corroboration.

Outcome: Applying this framework, the Court fixed the deceased’s annual income at ₹14 lakh (reflecting his business’s upward trend) and enhanced the compensation to ₹1.97 crore.

3. Supreme Court: Menstrual Hygiene Is a Constitutional Right, Not Just a Welfare Measure

Case: Dr. Jaya Thakur v. Government of India & Ors., 2026 INSC 97 | W.P. (C) No. 1000 of 2022 Bench: Justices J.B. Pardiwala and R. Mahadevan

Background: Social worker Dr. Jaya Thakur filed a PIL under Article 32 seeking free sanitary pads, separate functional toilets, hygiene awareness programmes, and safe disposal mechanisms for girl students in Classes VI–XII across government and government-aided schools. The petition highlighted how inadequate menstrual hygiene management drives absenteeism and dropout among adolescent girls. Though the Union placed its Menstrual Hygiene Policy for School Going Girls before the Court, and several states cited existing schemes, implementation on the ground remained grossly inadequate.

Held: Allowing the petition, the Supreme Court held that access to menstrual hygiene facilities is not merely a public health issue but a constitutional one, engaging the right to equality (Article 14), life with dignity (Article 21), and education (Article 21A). The absence of functional toilets, sanitary products, and disposal mechanisms disproportionately affects girl students, amounting to structural discrimination that keeps them from meaningfully participating in education.

Four key principles emerging from the judgment:

  1. The right to education isn’t satisfied by mere enrolment — it requires continuous, barrier-free participation, meaning schools must actively remove structural obstacles.
  2. True equality under Article 14 is substantive, not just formal — biological differences that create real disadvantages demand affirmative State action, not identical treatment.
  3. Dignified menstrual health is inseparable from the right to life, dignity, privacy, and bodily autonomy under Article 21, placing a positive obligation on the State (echoing the Puttaswamy privacy judgment).
  4. Failure to provide these facilities directly violates Article 21A and Sections 3 and 19 of the RTE Act, 2009 — and financial constraints cannot excuse non-compliance.

Obiter: The Court urged that menstruation be de-stigmatised, called for boys and male teachers to be included in awareness programmes (since social change can’t rest on educating girls alone), and situated education as a “multiplier right” underpinning the enjoyment of all other rights.

4. Supreme Court Permits Withdrawal of Life Support for Patient in Permanent Vegetative State, Refines Passive Euthanasia Guidelines

Case: Harish Rana v. Union of India, 2026 INSC 222 | Misc. Application No. 2238 of 2025 in SLP (Civil) No. 18225 of 2024 Bench: Justice J.B. Pardiwala

FACT: Harish Rana, a B.Tech student, suffered a severe brain injury in a 2013 fall and had remained in a Permanent Vegetative State ever since, sustained entirely through Clinically Assisted Nutrition and Hydration (CANH) via a PEG tube. Both the Primary and Secondary Medical Boards concluded his brain damage was irreversible with no realistic prospect of recovery. His parents approached the Supreme Court seeking to invoke the passive euthanasia framework from Common Cause v. Union of India (2018) to withdraw CANH.

Held: The Court ruled that CANH is properly classified as “medical treatment” — a technologically mediated medical intervention — rather than basic care that can never be withdrawn. This classification mattered enormously, because only medical treatment can lawfully be withdrawn under passive euthanasia principles. Passive euthanasia, the Court clarified, means allowing death to occur naturally by withdrawing treatment — it is not the physician creating a new risk of death, but stepping back and letting the underlying fatal condition take its course.

Since Harish Rana could not make decisions for himself, the Court applied the “best interest” principle, concluding that continued CANH merely prolonged biological existence without any reasonable prospect of recovery — and was therefore no longer in his best interests.

Institutional directions: AIIMS was directed to ensure the withdrawal process is accompanied by humane, pain-free palliative and end-of-life care. The Court also streamlined the procedural guidelines from Common Cause to make the process less burdensome for future cases, and urged Parliament to enact a dedicated end-of-life care law.

5. Supreme Court Orders Nationwide Crackdown on Stray Dogs After Suo Motu Cognizance of Rising Attacks

Case: In Re: “City Hounded by Strays, Kids Pay Price”, 2025 INSC 977 | Suo Motu W.P. (C) No. 5 of 2025

Background: The Supreme Court took suo motu notice of the escalating stray dog crisis across India — particularly the National Capital Region — after reports flagged over 37 lakh reported dog bites in 2024 and a rising rabies death toll, despite the Animal Birth Control Rules, 2023 already being in force. The Court examined whether releasing sterilised, immunised stray dogs back onto public streets was compatible with citizens’ fundamental rights under Articles 19(1)(d) and 21.

HELD: Protecting human life and public safety is the State’s primary constitutional obligation, and where fundamental rights under Article 21 are directly threatened, the State must act. The Court directed Delhi/NCR authorities to immediately begin capturing stray dogs, build adequate shelters within eight weeks, maintain detailed records, set up dog-bite helplines, and ensure sterilisation, immunisation, and veterinary care — with a clear prohibition on releasing captured dogs back onto public streets. Non-compliance was warned to invite contempt proceedings.

Obiter: The Court was careful to stress that humane treatment of sheltered dogs remains non-negotiable — adequate food, medical care, and no cruelty — and encouraged citizens who care about animal welfare to adopt or volunteer at shelters. It also observed that judicial decisions must be guided by constitutional values, not public sentiment.

Part II: High Court Watch

6. Delhi High Court Grants Ex Parte Injunction Against AI Chatbots Misusing Sonakshi Sinha’s Persona

Case: Sonakshi Sinha v. Character Technologies Inc. & Others, CS(COMM) 275/2026, Delhi High Court Bench: Justice Jyoti Singh (order dated 20 March 2026)

Background: Actress Sonakshi Sinha filed a commercial suit against multiple defendants — AI chatbot platforms, e-commerce websites, unidentified John Doe defendants, domain registrars, and government authorities — alleging unauthorised use of her name, image, voice, and likeness. Some AI chatbots were generating conversations using her persona, including obscene and sexually explicit content; several commercial websites were using her photographs to falsely suggest product endorsements.

Held: Delhi High Court has repeatedly recognised personality rights, and reaffirmed that a celebrity has the exclusive right to control her name, likeness, and other identifiable attributes — no third party may exploit them without consent. Unauthorised use of AI tools — chatbots, deepfakes, generative AI, face morphing — to imitate a celebrity’s persona without authorisation was held to be unlawful exploitation warranting injunctive relief. Finding a strong prima facie case, irreparable harm, and balance of convenience in her favour, the Court granted an ex parte ad interim injunction restraining the defendants and directed removal of infringing content within 36 hours.

Court observations: The Court flagged that AI-generated obscene content using her likeness seriously tarnishes dignity and reputation, warranting urgent intervention, and reiterated that a celebrity’s endorsement rights are a significant commercial asset — false endorsement causes both commercial loss and a violation of privacy and dignity.

7. Orissa High Court Dismisses Habeas Corpus Petition Filed to Compel Wife’s Return, Imposes Costs

Case: Shri Lambodar Patra v. State of Odisha and Others, WPCRL No. 71 of 2026, High Court of Orissa Bench: Chief Justice Harish Tandon and Justice Murahari Sri Raman (decided 22 June 2026)

Fact: The petitioner sought a writ of habeas corpus, alleging his wife had been kidnapped and was being wrongfully confined. However, his own annexed pleadings undercut his case: they revealed he had personally met his wife at the alleged “kidnapper’s” residence, asked her to return, and she had voluntarily refused.

Held: Since the wife was a major who had left the matrimonial home of her own free will due to marital discord, habeas corpus was not maintainable — the petition was really an attempt to use extraordinary writ jurisdiction to pressure her back rather than to address any genuine unlawful detention. The Court held that:

  • Habeas corpus cannot be used to resolve matrimonial disputes or force an adult spouse to return home;
  • An adult woman is fully competent to decide where and with whom to live, and her voluntary choice to live separately cannot constitute kidnapping or unlawful confinement;
  • A petitioner who suppresses material facts or manufactures an artificial cause of action does not come to court with clean hands and forfeits relief.

Outcome: The petition was dismissed with costs of ₹50,000, to be deposited with the State Legal Services Authority for use towards juveniles, within two weeks.

Court observations: The Bench flagged a broader trend of habeas corpus petitions being misused to settle personal scores once matrimonial relations sour, rather than to address genuine illegal detention.

8. Punjab & Haryana High Court Declines Protection to Live-in Couple Where Legal Prerequisites Weren’t Met

Case: Lisha v. State of Punjab, 2026, Punjab & Haryana High Court Bench: Justice Sandeep Moudgil

Background: Two adults in a live-in relationship approached the High Court under Article 226 seeking police protection from interference by their families, contending they intended to marry and feared threats. Their own petition, however, disclosed that the male petitioner had not yet attained the legally marriageable age.

Held: Article 21 guarantees life, liberty, and dignity, but these rights aren’t absolute — they must be exercised within the framework of law. Relying on the Supreme Court’s test in D. Velusamy v. D. Patchaiammal (2010) — which requires partners in a relationship “in the nature of marriage” to hold themselves out as spouses and be legally qualified to marry — the Court found the essential prerequisites missing here, since one partner was under the marriageable age. It also invoked NALSA v. Union of India (2014) on constitutional dignity, but balanced this against parents’ equal right to live with dignity, noting that constitutional freedoms must operate within legally recognised boundaries.

Key distinction drawn: The Court separated genuine live-in relationships (which do merit constitutional protection) from relationships resting solely on unsubstantiated assertions of cohabitation — cautioning that extending protection based on bare claims risks judicially legitimising relationships that don’t meet legal standards.

Outcome: Writ petition dismissed; no police protection granted.

Part III: Policy & Institutional Development

9. Ministry of Law & Justice Adopts ‘Sankalp Patra’ at Reforms Utsav & Chintan Shivir 2026

The Ministry of Law and Justice concluded a two-day “Reforms Utsav & Chintan Shivir 2026” (4–5 July 2026) at Gyan Sarovar, Mount Abu, jointly organised by the Department of Legal Affairs and the Legislative Department. The event brought together senior officers to deliberate on legal, legislative, and institutional reform, and concluded with the adoption of the Mount Abu Declaration, released as the “Sankalp Patra.”

Inauguration and vision: The event was inaugurated by Union Minister of State (Independent Charge) for Law and Justice, Shri Arjun Ram Meghwal, who framed it as an opportunity to review recent achievements and chart a long-term reform strategy. Dr. Rajiv Mani, Secretary of the Department of Legal Affairs and Legislative Department, outlined a vision for an efficient, accessible, and future-ready legal system aligned with the Viksit Bharat @2047 goal.

Thematic focus areas: Breakout sessions covered digital transformation, legislative reform, institutional capacity building, adoption of Artificial Intelligence, Alternative Dispute Resolution (ADR), litigation management, and technology-enabled public service delivery. Participants also examined how to simplify legislative drafting and strengthen it through evidence-based approaches.

Valedictory session: The concluding day featured a motivational address by Sister Sheilu on “Swaparivartan se Vishwaparivartan” (self-transformation leading to global transformation), followed by the Valedictory and Sankalp Session, themed “Convergence, Accountability and a Shared Reform Roadmap.” Recommendations from four breakout groups were consolidated into a unified reform framework.

Key commitments in the Sankalp Patra:

  • Promoting professionalism, innovation, and continuous learning in legal and legislative governance;
  • Simplifying laws and legal processes to make them more citizen-centric and accessible;
  • Ensuring quality, consistency, and evidence-based legislative drafting;
  • Responsibly adopting digital technologies and AI to build future-ready legal institutions;
  • Fostering a culture of reflection, collaboration, and continuous institutional reform;
  • Strengthening inter-departmental convergence, litigation management, and ADR promotion.

In his valedictory address, Shri Meghwal stressed that reforms must translate into measurable outcomes, noting that delayed justice ties up national resources and hampers economic development — and called on all departments to coordinate closely in implementing the reform agenda.

Exam View: For anyone tracking India’s institutional legal reform trajectory, the Sankalp Patra is a useful signpost of where the Law Ministry’s policy priorities — AI adoption, ADR, and legislative simplification — are headed through 2047.

Key Takeaways for the Week

  • AI and courts: The Supreme Court drew a hard line on unverified AI-generated precedents (NCLT/NCLAT case) while the Delhi High Court moved decisively against AI misuse of personality rights (Sonakshi Sinha case) — together, a clear signal that Indian courts are actively building AI-accountability jurisprudence.
  • Article 21 keeps expanding: From menstrual hygiene (Jaya Thakur) to the right to die with dignity (Harish Rana) to public safety from stray dogs, Article 21 continues to be the vehicle for significant substantive rulings.
  • Writ jurisdiction has limits: Both the Orissa and Punjab & Haryana High Courts this week reinforced that Articles 226 relief requires more than bare assertions — courts will look behind the pleadings.
  • Compensation law gets clearer: The ITR guidelines in Rashmirekha Tripathy should now be a standard reference point in motor accident claims practice.

Thank You LegalRath Team!