Introduction:

The increasing use of Artificial Intelligence (AI) has created new opportunities in several fields, but it has also raised serious concerns about the misuse of technology to create misleading or fabricated documents. The Allahabad High Court recently confronted one such issue when a high school marksheet, allegedly manipulated and apparently generated using AI, was produced during proceedings in a writ petition concerning police harassment arising out of a marriage solemnised at an Arya Samaj temple in Lucknow.

A Division Bench comprising Justice Rajnish Kumar and Justice Babita Rani took serious note of discrepancies between two marksheets placed before it. The Court observed that the production of a forged or manipulated document in judicial proceedings was not merely an issue concerning the authenticity of an individual record. Such conduct could undermine the dignity of the institution, weaken litigants’ confidence in the justice system and adversely affect the administration of justice.

Taking note of the apparent manipulation, the Bench described the disputed document as a “fruit of poisonous tree” and directed the Commissioner of Police, Lucknow, to appoint an officer not below the rank of Deputy Commissioner of Police (DCP) to conduct a detailed inquiry. The investigation was intended to identify the persons responsible for preparing the document and determine whether anyone else was involved in its creation or use.

The writ petition had been filed by Neha Pandey and another petitioner, who alleged that they were being harassed by the police in connection with their marriage. According to the petitioners, their marriage had been solemnised at an Arya Samaj temple in Lucknow on September 4, 2026. During the hearing, however, the Court noticed an inconsistency in the date of birth of petitioner No. 2, which subsequently led to the discovery of substantial differences between two documents purporting to be his high school marksheet.

The controversy raised an important concern regarding the integrity of documents submitted before constitutional courts. Judicial proceedings depend upon the accuracy and authenticity of the material placed on record. When a document is suspected to have been fabricated or digitally manipulated, the Court cannot simply disregard the issue, particularly where the document may have influenced the circumstances surrounding the dispute.

The order also brings attention to the challenges that courts may face as AI-based tools become increasingly accessible. Although technology can assist in creating and processing documents, its use to manufacture apparently official records or alter material information may have serious legal consequences. The High Court’s intervention was therefore directed not only towards examining the particular marksheet but also towards establishing how it came to be prepared and produced before the Court.

Arguments of the Parties:

The principal dispute before the High Court arose from the petitioners’ allegation that they were being harassed by the police in connection with their marriage. Their writ petition sought the Court’s intervention in relation to the circumstances surrounding the marriage solemnised at an Arya Samaj temple in Lucknow on September 4, 2026.

During the proceedings, the Court noticed that the high school marksheet annexed to the writ petition recorded the date of birth of petitioner No. 2 as July 29, 2006. However, the marriage certificate issued by the Arya Samaj mentioned his date of birth as July 29, 2005. The discrepancy was significant because the documents reflected different years of birth for the same individual.

In view of this inconsistency, the Court directed the Secretary of Arya Samaj, Sector Q, Aliganj, Lucknow, and the priest who had solemnised the marriage to appear before it with the relevant records. The direction was intended to enable the Court to verify the documents relied upon at the time of solemnising the marriage and understand the circumstances in which the date of birth had been recorded.

On September 22, the Secretary of the Arya Samaj appeared and produced a high school marksheet. According to him, the document had been furnished by petitioner No. 2 for the purpose of solemnising the marriage. The Court compared this marksheet with the document annexed to the writ petition and noticed several differences.

Apart from the variation in the date of birth, the certificate numbers appearing on the two documents were also different. The Court further noticed a significant difference in the language of the transcripts. While the marksheet filed with the writ petition contained a transcript in Hindi, the corresponding transcript in the document produced by the Secretary was in a language that was neither Hindi nor Sanskrit.

These discrepancies raised questions about the authenticity of the document produced by the Arya Samaj Secretary and the manner in which it had been prepared. The Court consequently directed the petitioners to appear in person and ordered that the documents and register produced by the Secretary be kept in a sealed cover.

When petitioner No. 2 appeared personally, he claimed that he had supplied a copy of his original high school marksheet to the Arya Samaj authorities. According to his explanation, the original document recorded his date of birth as July 29, 2006. This was consistent with the date of birth mentioned in the marksheet annexed to the writ petition, but differed from the date appearing in the document produced by the Secretary.

The competing versions therefore created an important question: how had a marksheet showing a different date of birth and other distinct features come into the possession of the Arya Samaj Secretary? If petitioner No. 2 had supplied only his original marksheet, the circumstances in which the other document had been prepared or obtained required further examination.

The Court noted that the explanation offered by petitioner No. 2 and the document produced by the Secretary could not be reconciled merely by overlooking the differences. The discrepancy in the certificate numbers, the altered date of birth and the difference in the transcript’s language collectively called for a proper inquiry.

The available case summary does not record detailed written submissions or a separate set of arguments advanced by the State on the suspected fabrication. Nor does it indicate that the Court had reached a final finding identifying petitioner No. 2, the Arya Samaj Secretary, the priest or any other individual as responsible for preparing the disputed document. The issue before the Bench at this stage was whether the apparent manipulation warranted an independent and sufficiently senior police inquiry.

Accordingly, the Court proceeded on the basis of the material discrepancies and the explanations placed before it, while leaving the question of responsibility to be determined through an investigation.

Court’s Judgment:

The Allahabad High Court treated the suspected fabrication of the marksheet as a serious matter requiring investigation beyond the immediate dispute raised in the writ petition. The Bench observed that the differences between the two documents were not minor or insignificant. They concerned essential identifying particulars, including the date of birth and certificate number, as well as the language of the academic transcript.

Upon examining the marksheet produced by the Arya Samaj Secretary, the Court observed that the document appeared, prima facie, to have been manipulated. It further noted that the certificate apparently seemed to have been prepared using Artificial Intelligence. According to the Court’s observation, the Hindi transcript could not be found in the disputed certificate because of the technical application used in its preparation.

The observation was significant because it suggested that the document might not have been a genuine academic record merely containing an accidental clerical error. Rather, its features indicated possible digital alteration or artificial generation. Nevertheless, the Court did not treat this initial assessment as a substitute for a formal investigation. It considered the circumstances sufficiently serious to warrant an inquiry into the document’s origin, preparation and subsequent use.

The Bench expressed surprise that a manipulated and apparently AI-generated marksheet had been produced before a constitutional court. It described the document as a “fruit of poisonous tree”, emphasising the seriousness of placing potentially fabricated material before a judicial institution.

The expression conveyed the Court’s concern that a document whose authenticity was fundamentally doubtful could contaminate the judicial process if relied upon without verification. Courts adjudicate disputes on the basis of pleadings, evidence and material placed before them. The integrity of that process depends upon parties and persons producing records acting honestly and ensuring that documents presented as genuine are, in fact, authentic.

The Bench also considered the explanation given by petitioner No. 2. He had stated that he supplied his original marksheet, which recorded his date of birth as July 29, 2006. The Court observed that if he had actually supplied the manipulated and AI-generated marksheet to the Arya Samaj Secretary, there would have been no occasion for him to file his original high school marksheet along with the writ petition.

This observation highlighted the central uncertainty in the matter. The document produced by the Secretary was materially different from the one filed by petitioner No. 2. The difference could not be conclusively explained merely by referring to the date of birth recorded in the marriage certificate. It was necessary to ascertain who had prepared the disputed marksheet, how it had reached the Arya Samaj authorities and whether it had been deliberately created or altered for a particular purpose.

The Court made it clear that the issue could not be left unresolved. It observed that the preparation of a forged and manipulated marksheet showing petitioner No. 2’s date of birth as July 29, 2005, had become a matter requiring an appropriate answer. Since the document had been produced in judicial proceedings, the Court considered itself duty-bound to address the issue rather than remain a silent observer.

In this context, the Bench made a broader observation about the consequences of producing fabricated documents before courts. It stated that presenting a manipulated, forged and AI-generated document not only tends to tarnish the dignity of the institution but also shakes a litigant’s trust and adversely affects the justice dispensation system.

The Court’s concern extended beyond the immediate question of whether the petitioners’ date of birth had been correctly recorded. A forged document placed before a court can potentially mislead judicial authorities, influence the assessment of disputed facts and consume valuable judicial time. It can also create difficulties for other persons whose rights or interests may depend upon the authenticity of the record. The deliberate use of fabricated material, if established, therefore raises concerns about the administration of justice itself.

The order is particularly relevant in the context of the growing accessibility of AI-based applications. Such tools can generate or modify text, images and document layouts with increasing sophistication. However, the ability to create a document that resembles an official certificate does not confer authenticity upon it. A digitally generated or modified record cannot acquire the legal status of a genuine academic document merely because it appears convincing or is presented as an original.

At the same time, the Court’s observations at this stage must be understood in their proper procedural context. The Bench expressed a prima facie view that the disputed marksheet appeared manipulated and AI-generated. It did not, on the basis of the material then available, conclusively determine who was responsible for its preparation or whether any particular person had committed an offence. Those questions were left open for investigation.

Considering the seriousness of the matter, the Court, by its order dated September 25, directed the Commissioner of Police, Lucknow, to appoint a competent police officer not below the rank of Deputy Commissioner of Police within one week. The officer was directed to conduct a detailed inquiry into the preparation of the disputed document and identify the persons involved in its creation.

The direction for an inquiry by an officer of at least DCP rank reflected the Court’s expectation that the matter should receive appropriate institutional attention. The inquiry was not to be confined to merely comparing the two marksheets. It was required to examine the circumstances in which the allegedly forged document had been prepared and determine the involvement or complicity, if any, of the persons connected with it.

The Bench further directed that both petitioners, the Secretary of Arya Samaj, Sector Q, Aliganj, and the priest who had solemnised the marriage must remain present before the Inquiry Officer whenever required. This direction ensured that the persons connected with the marriage and the relevant documentation would be available to assist the inquiry. Their presence would enable the officer to examine the source of the marksheet, the records maintained by the Arya Samaj and the circumstances in which the disputed document had been submitted.

The Court also called for a report setting out the findings of the inquiry, particularly with regard to the involvement or complicity of the persons responsible for preparing the forged document. The report was directed to be submitted within four weeks thereafter. The matter was listed for November 12 for further consideration.

The order does not record any final criminal conviction or determination of guilt against the petitioners, the Arya Samaj Secretary, the priest or any other person. Instead, it establishes a fact-finding process intended to identify the source of the suspected forgery and clarify the circumstances in which it came to be placed before the Court. Any further legal consequences would depend upon the findings of the inquiry and the applicable law.

The case also highlights the importance of preserving the distinction between a court’s preliminary observations and a final adjudication. A prima facie finding that a document appears manipulated is sufficient to justify verification and investigation, but responsibility must ultimately be established through a fair process and reliable evidence. The Court’s decision to order an inquiry, rather than conclusively attribute the alleged fabrication to a particular individual, reflects the need to establish the facts before further action is taken.

More broadly, the proceedings serve as a reminder that the authenticity of documents is central to the administration of justice. Whether a document is prepared manually or with the assistance of digital technology, its contents and origin must be genuine when it is presented as an official record. The misuse of AI to create or alter documents, if established, cannot be treated as a harmless technological exercise when such material is intended to influence legal proceedings.

By directing a DCP-level inquiry, the Allahabad High Court has made clear that suspected fabrication of judicial records or documents produced before it cannot be ignored. The investigation will determine how the disputed marksheet was prepared, who was responsible and whether any person was involved in its production or use. The matter remains subject to the outcome of that inquiry and further proceedings before the Court.