Towards a Framework for Judicial AI Sovereignty: Lessons from Asian Courts

Abstract

As artificial intelligence (AI) becomes embedded in judicial systems worldwide, courts face a fundamental question: can judiciaries that rely on opaque algorithmic tools developed by external actors remain truly sovereign? This article develops the concept of judicial AI sovereignty, defined as courts’ institutional capacity to retain meaningful control over algorithmic systems that shape legal outcomes, reflect legal traditions, preserve judicial independence, and maintain legitimacy. Drawing on extensive mapping of AI deployment in Asian courts by the Oxford Institute of Technology and Justice, the article examines three emerging governance models. China exemplifies a centralised coordination model with top-down integration; India reflects fragmented, crisis-driven experimentation without unified oversight; and Singapore illustrates a controlled innovation model centred on cautious piloting and judicial self-regulation. These trajectories expose shared tensions between efficiency and sovereignty that resonate globally. Building on these insights, the article proposes a seven-dimensional framework for evaluating judicial AI sovereignty.