A Tree-of-Thoughts Inspired Hybrid Approach for Legal Case Judgement Summarization using LLMs

Large language models (LLMs) now support contexts of up to 1M tokens, but their strengths and weaknesses on complex long-context tasks remain unclear. To study this, we focus on multi-document legal case summarization, where a single case often spans many documents exceeding 100K tokens. We systematically evaluate 12 frontier LLMs with Gavel, which consists of Gavel-Ref, a reference-based evaluation framework with checklist, residual-fact, and writing-style evaluations, and Gavel-Agent, a reference-free agent for evaluating factual coverage directly from source documents. Our results show that current models are more prone to omitting key information than hallucinating. They all perform well on simple checklist items, such as filing date, but struggle with rare and complex items, such as settlements. Performance also declines as case length increases. To meta-evaluate Gavel, we collect 160 hours of human annotations. Gavel-Agent reduces token usage by at least 36% compared to end-to-end and chunk-by-chunk methods while achieving competitive performance. Gavel-Agent also generalizes to the medical domain, performing the best with at least 77% fewer tokens.

We show that sequence-level distillation from a capable long-context teacher model is a simple, annotation-free, and data-efficient strategy for improving argument saliency coverage in long legal opinion summarization, where small LLMs often struggle to retain the most salient argumentative content. Across student model sizes, distillation consistently surpasses tuning on expert-written summaries in our legal-opinion setting. We further demonstrate that most gains are achieved with as few as ~10 training summaries, highlighting the strong data efficiency of teacher-generated supervision. Finally, we find that summary distillation is sufficient for improvements: reasoning-chain distillation remains competitive with summary-only distillation, but provides marginal benefit when combined with summary supervision.

Reliable evaluation of large language model (LLM)-generated summaries remains an open challenge, particularly across heterogeneous domains and document lengths. We conduct a comprehensive meta-evaluation of 14 automatic summarization metrics and LLM-based evaluators across seven datasets spanning five domains, covering documents from short news articles to long scientific, governmental, and legal texts (2K-27K words) with over 1,500 human-annotated summaries. Our results show that traditional lexical overlap metrics (e.g., ROUGE, BLEU) exhibit weak or negative correlation with human judgments, while task-specific neural metrics and LLM-based evaluators achieve substantially higher alignment, especially for linguistic quality assessment. Leveraging these findings, we propose LLM-ReSum, a self-reflective summarization framework that integrates LLM-based evaluation and generation in a closed feedback loop without model finetuning. Across three domains, LLM-ReSum improves low-quality summaries by up to 33% in factual accuracy and 39% in coverage, with human evaluators preferring refined summaries in 89% of cases. We additionally introduce PatentSumEval, a new human-annotated benchmark for legal document summarization comprising 180 expert-evaluated summaries. All code and datasets will be released in GitHub.