How we check a citation: what happens when you paste a draft into Nira

Before you file, check four things about every authority: it exists and is the case you named; each quotation is word for word and at the para you give; the words are the court's, not counsel's or another judge's; and the case has not been stayed, reversed or overridden since. Nira's citation check reports on all four for a pasted draft: whether the authority is found and is the case named, whether each quotation is word for word and at the para you cite, whose words they are, and any dated status flag. It marks each authority ok, review or problem.

What does Nira check when you paste a draft?

Paste a reply, a show cause notice or an order. The check is read-only: it reads the text you paste and returns a report. It does not change your draft. For each authority it reports:

• Held, and the case you named. It resolves a neutral citation, reporter citation, case number or party name, then compares the name, year and court you wrote with the record.
• Word for word, and at which para. Put each quotation in quotation marks: the check reads text between them and compares it with the cited judgment. The result is word for word, close but altered (the differing words named) or not found, with the para where the words sit. If your draft gives a different para, the report says so and names the right one.
• Whose words. The passage is read as the court's own, a party's submission, the order under challenge, or a decision the court is quoting.
• Later history. Dated status flags (appealed, stayed, overruled, legislatively overridden) recorded for the authority. Any flag lifts the row to review; a practitioner-reviewed flag of overruled, reversed, stayed or similar that matches the point you cite the case for makes it a problem.

Each gets a level: ok, review or problem; a row that could not be read is unchecked. We run every article in this library through the check before publication, this one included.

Does the citation exist, and is it the case you named?

A draft can carry a plausible name with a number that leads nowhere, or a real number under the wrong name. We invented a party and tried both.

Ashgrove is an invented name. We make no claim about whether 2022 INSC 1187 exists elsewhere.

"Not found" is a review, because no index holds every judgment: go to the court's website or the reporter. A real number under a wrong name is a problem: it leads to a different case, so the sentence has no authority.

Is the quotation word for word?

In Kesari Nandan Mobile v. Office of Assistant Commissioner of State Tax (2), Enforcement Division – 5 (Civil Appeal No. 9543 of 2025, 14 August 2025, 2025 INSC 983), the Supreme Court said of section 83 of the CGST Act that "any order of provisional attachment, issued under sub-section (1), would cease to have any effect after a period of a year" (para 19). We altered two words.

Bold is ours, to mark the altered word. Printed line shortened.

"May cease" turns a lapse by operation of law into a possibility, yet the sentence reads smoothly. The report names each differing word.

Is it at the para you wrote?

Here the words are exact and the para is not.

Para 31 is ours. The words are the Court's, from para 19.

The words are right, so the quotation is not marked altered; the pin cite is wrong, so the row is a review. A bench turning to para 31 will not find your sentence. Para 31 of the judgment is about a fresh attachment order on the same grounds, not the one-year lapse.

Whose words are they: the court's, a party's, or another decision's?

A judgment records arguments and quotes earlier decisions; those passages are not, as such, what this court held on the point. We quoted one of each.

Case name shortened in the first row.

Para 12 of Kesari Nandan records the respondent's counsel's contention. The Court held the other way (2025 INSC 983, para 41): "We hold that the respondent could not have issued the impugned provisional attachment orders dated 13th November, 2024 and 18th December, 2024".

Para 29 of Quippo Energy (a central excise judgment of 19 September 2025) reproduces an observation from the earlier decision in Servo-Med; para 30 records the Court's "respectful agreement". Cite Servo-Med (Servo-Med Industries Pvt. Ltd. v. Commissioner of Central Excise, Mumbai, 7 May 2015, 2015 INSC 391, para 24) for the passage. The speaker is read by rules from the passage and its para, so open the para whatever the level says.

Has the case been stayed, reversed or overridden since?

Section 17(5)(d) of the CGST Act blocks credit on goods or services received for constructing an immovable property, other than plant and machinery, on one's own account. We quoted the Supreme Court's 2024 reading of the section's earlier wording.

Output shortened; the bold labels are ours, and the second flag is described below.

The quotation is right and the case needs a second look. Section 124 of the Finance Act, 2025 substituted "plant and machinery" for "plant or machinery" in section 17(5)(d), deemed from 1 July 2017, and added an Explanation that any reference to "plant or machinery" "shall be construed and shall always be deemed to have been construed as a reference to 'plant and machinery'" despite "any judgment, decree or order of any court, tribunal, or other authority". Nira's note adds that how far the override reaches is still argued. The same record notes that the Supreme Court dismissed the government's review petition in May 2025. Neither flag is yet confirmed by a practitioner, so the row is a review, not a problem. A case with no flag still needs the checks below.

Does the case say what you say it says?

Not every error is in the words. We typed a sentence with no quotation marks.

Our sentence is wrong on purpose. Cell shortened and assembled from the report's summary, citation line and holding block; the label is ours.

The level is ok because the citation is right. The holding line shows the sentence is wrong: the appeal was allowed. Reading the outcome against your sentence is your job.

What should I check before I file, with or without Nira?

Frequently asked questions

Sources

• Judgments Supreme Court: Civil Appeal No. 9543 of 2025 (2025 INSC 983, paras 12, 19, 41); No. 9418 of 2016 (2025 INSC 1130, paras 29, 30); No. 2948 of 2023 (2024 INSC 756, para 44); No. 583 of 2005 (2015 INSC 391, para 24).
• Statute CGST Act section 17(5)(d) and Explanation 2; Finance Act, 2025, section 124.