What was hallucinated

Fabricated: Case Law | Respondent's counsel cited 'Sekunda Magope v. Njelu Magope [1983] TLR 141' to support their position; court found the cited case non-existing and that the report at that page is actually Republic v. Mt. 12153 L/Cpl. Wagenyi [1983] TLR 141. || Fabricated: Case Law | Respondent's counsel cited 'Hatia John v. Mohamed Msuya [2005] TLR 149'; court found this citation non-existent and the actual report at those pages is Kalunga & Co. Advocates v. National Bank of Commerce Ltd [2005] TLR 148-153. || Fabricated: Case Law | Respondent's counsel cited 'Aisha Omari v. Omari Iddi [1983] TLR 339'; court found no such authority at that page, noting the relevant report around that page is Issa Athumani Mduyah v. Republic [1983] TLR 336. || Fabricated: Case Law | Respondent's counsel cited 'Mariamu Adam v. Rukia Issa [1997] TLR 54'; court found the citation non-existent and the actual report at that page is Hamed Rashid Hamed v. Mwanasheria Mkuu & Others [1997] TLR 53. || Misrepresented: Case Law | Counsel relied on Bibie Mauridi v. Mohamed Ibrahim [1989] TLR 162 to support a proposition on distribution, but the court held that the cited case did not support that proposition (misrepresentation of the holding).

Details

"Before getting into the nitty gritty of the issue above, as indicated when making reference to authorities cited by counsels for the respondent to this court, it behoves to say out of all cases referred, were non-existing and did not support the preposition. I have to emphasize that all lawyers have duties to the court, to their clients and to the administration of justice, duty to faithfully represent the law to the court, duty not to fabricate case precedents and not to mis-cite cases for propositions that they do not support and duty to use technology, conduct legal research, and prepare court documents competently. [...]Without being to repetitive, advocates have a duty to ensure they do not mislead the court, whether through their own actions or failures to act, or by enabling or participating in any misleading conduct by their clients. The proper functioning of the justice system relies on the court’s ability to trust the honesty and integrity of legal practitioners, as well as their professional responsibility to present only arguments that are legitimately supported."

Sanction teardown · High Court, Tanzania · 2025-07-15

FAM v ZAM

What happened

In High Court, Tanzania, 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:

Fabricated (Case Law)

Respondent's counsel cited 'Sekunda Magope v. Njelu Magope [1983] TLR 141' to support their position; court found the cited case non-existing and that the report at that page is actually Republic v. Mt. 12153 L/Cpl. Wagenyi [1983] TLR 141.
Fabricated (Case Law)

Respondent's counsel cited 'Hatia John v. Mohamed Msuya [2005] TLR 149'; court found this citation non-existent and the actual report at those pages is Kalunga & Co. Advocates v. National Bank of Commerce Ltd [2005] TLR 148-153.
Fabricated (Case Law)

Respondent's counsel cited 'Aisha Omari v. Omari Iddi [1983] TLR 339'; court found no such authority at that page, noting the relevant report around that page is Issa Athumani Mduyah v. Republic [1983] TLR 336.
Fabricated (Case Law)

Respondent's counsel cited 'Mariamu Adam v. Rukia Issa [1997] TLR 54'; court found the citation non-existent and the actual report at that page is Hamed Rashid Hamed v. Mwanasheria Mkuu & Others [1997] TLR 53.
Misrepresented (Case Law)

Counsel relied on Bibie Mauridi v. Mohamed Ibrahim [1989] TLR 162 to support a proposition on distribution, but the court held that the cited case did not support that proposition (misrepresentation of the holding).

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

Reminder of lawyer's duties

Additional detail

"Before getting into the nitty gritty of the issue above, as indicated when making reference to authorities cited by counsels for the respondent to this court, it behoves to say out of all cases referred, were non-existing and did not support the preposition. I have to emphasize that all lawyers have duties to the court, to their clients and to the administration of justice, duty to faithfully represent the law to the court, duty not to fabricate case precedents and not to mis-cite cases for propositions that they do not support and duty to use technology, conduct legal research, and prepare court documents competently. [...]Without being to repetitive, advocates have a duty to ensure they do not mislead the court, whether through their own actions or failures to act, or by enabling or participating in any misleading conduct by their clients. The proper functioning of the justice system relies on the court’s ability to trust the honesty and integrity of legal practitioners, as well as their professional responsibility to present only arguments that are legitimately supported."

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.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/757/FAM_vs_ZAM_2025_TZHC_3948_15_July_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).