Can technology augment order writing capacity at regulators?

This paper critically examines the opportunities and challenges of using technology, in particular Large Language Models (LLMs), to assist regulatory order writing in quasi-judicial settings, with a focus on the Indian context. The paper proposes augmenting rather than replacing human decision-makers, aiming to improve regulatory order writing practice through responsible use of LLMs. It identifies the core principles of administrative law that must be upheld in these settings — such as application of mind, reasoned orders, non-arbitrariness, rules against bias, and transparency — and analyses how inherent limitations of LLMs, including their probabilistic reasoning, opacity, potential for bias, confabulation, and lack of metacognition, may undermine these principles.

CITATION

Natasha Aggarwal, Satyavrat Bondre, Amrutha Desikan, Bhavin Patel & Dipyaman Sanyal, 2025. “Can technology augment order writing capacity at regulators?,” Working Papers 16, Trustbridge Rule of Law Foundation.

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