AI hallucination cases in Australia

Stewart v Good Shepherd Australia New Zealand

[2025] VSCA 206

Also recorded as Stewart v Good Shepherd.

Stewart v Good Shepherd Australia New Zealand [2025] VSCA 206
DetailWhat the trackers record
CourtSupreme Court of Victoria — Court of Appeal
JurisdictionVictoriaVictoria forum
Date29 August 2025
Who used AISelf-represented
Tool named by the trackersNot named
Sanction for the AI useNo professional sanction
OutcomeNot recorded
Citation[2025] VSCA 206

Summary from the trackers

OBITER

The litigant in person’s (Applicant’s) use of AI in written submissions, including fabricated authorities and citations; arguments supported in places by reference to non‑existent authorities; and references to passages in real authorities that bore no relationship to the argument (see [62]–[63]).

Charlotin database

Fabricated: Case Law | The applicant's written submissions included 'non-existent authority' citations (fabricated cases/authorities); the judge noted these as phantom authorities and said their inclusion did not help the applicant. || Misrepresented: Case Law | The applicant cited real authorities but relied on passages that bore no relationship to the arguments, which the judge described as misplaced or misapplied references.

Court AI rules

Sources

All AI hallucination cases in Australia · Victoria · Court AI practice notes