[Artificial Intelligence] Manipur High Court Uses Chat-GPT To Conduct Research & Pass Order In Service Law Matter

In a remarkable development, the Manipur High Court has employed the use of artificial intelligence to conduct research into a service law matter and pass a reasoned order. The petitioner was disengaged from being a member of the Village Defence Force (VDF) without affording an opportunity to be heard and without any enquiry on the allegation of dereliction of duty upon the escape of an accused from police custody. 

Earlier, the Punjab & Haryana High Court had become the first HC in the country to employ the use of AI to research before pronouncing its judicial pronouncements.

A single bench of Justice A Guneshwar Sharma was dealing with a matter concerning the service conditions Village Defence Force (VDF) and stated that while the Court had called for an explanation from the government counsel on procedures for disengagement of VDF personnel, the same was not forthcoming and the Court was compelled to do extra research through Google and ChatGTP 3.5 to collect important information regarding VDF.

By using Chat GPT, the Court stated that it found the following information relating to VDF:

The Village Defence Force, popularly known as VDF, in Manipur was established to enhance local security and assist the police in maintaining law and order, especially in the rural areas. Initiated under the Manipur Police, the VDF consists of volunteers from the local communities who are trained and equipped to guard their villages against various threats, including insurgent activities and ethnic violence. After completing the training successfully and passing any required assessments, the candidates are formally appointed as members of VDF. Once appointed, VDFs are assigned duty along with the police force. However, there is no material on record regarding the service conditions of VDF personnel. 

Upon further research, the Court came across an office memorandum on the service conditions of VDF personnel as well as the case of Nasim Bano v. The State of Manipur & Ors [WP(C) No.209 of 2023] which dealt with a similar subject matter.

It was stated that in the present case, the dis-engagement order (ie, removal from service) was issued on 02.01.2021 itself, the day on which the accused had escaped from police custody without affording any opportunity of hearing to him.

Court noted that the enquiry was conducted only on 08.01.2021, where some of the regular police personnel were awarded with minor penalty. The petitioner was awarded a major penalty of removal from service without any show cause and enquiry. Accordingly, in setting aside the order of removal, it held:

This Court is of the opinion that the disengagement order dated 02.01.2021 passed by the Superintendent of Police, Thoubal is in violation of the principles of natural justice as held in the case of Nasim Banu. Judicial note is taken about the subsequent Office Memorandum dated 18.10.2022 stipulating brief service conditions of VDF personnel. In the circumstances, the impugned order dated 02.01.2021 disengaging the petitioner from the strength of Thoubal District VDF is set aside and the petitioner is restored to the strength and roll of VDF Thoubal with immediate effect.

Citation: 2024 LiveLaw (Man) 4

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