Sanction teardown · ON SCSM, Canada · 2026-05-04
Ashish Yadav v. Anoshan Ahangama and Ahangama Law Professional Corporation
What happened
In ON SCSM, Canada, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:
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Misrepresented (Exhibits & Submissions)Defence counsel produced a one-page 'Database Document' labeled 'page 1 of 5' but initially withheld the other pages; court found the exhibit incomplete and misleading.
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Misrepresented (Case Law)Database Document listed 'Schroder v. All Languages' as awarding 1 week notice when the actual award was about $6,000; court found the description inaccurate.
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Misrepresented (Case Law)Database Document listed 'Bryczkowski v. Dennison Associates' as a 3-month notice award though that action was dismissed; court identified the entry as inaccurate.
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Fabricated (Case Law)Multiple cases listed in the Database Document could not be located in reported law and 'may not even exist', suggesting fabricated entries.
Which AI tool
an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.
Outcome
Not specified in source record.
Additional detail
Defence counsel (Mr. Gorrin) submitted a one-page 'Database Document' listing cases relevant to notice. The court discovered it was page 1 of 5, and the full 5-page document (later produced) contained additional cases and showed inconsistent search criteria. The court found many case descriptions in the Database Document inaccurate, some cases could not be located (and may be fabricated), and therefore the document was unreliable and was not given weight. No professional sanction or monetary penalty was imposed; the court simply rejected the document as an unreliable exhibit.
How Citation Safe would have caught this
Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.
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Source: https://www.damiencharlotin.com/documents/2223/Yadav-v-Ahangama-2026-CanLII-48313-ON-SCSM.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).