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Was Geha Enterprises Pty Ltd v Deuteronomy 28 Investments Pty Ltd and Registrar General of the ACT on the other side of your case?

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Geha Enterprises Pty Ltd v Deuteronomy 28 Investments Pty Ltd and Registrar General of the ACT

Court
ACT SC
Jurisdiction
Australia
Decided
2026-04-21
AI tool
Unidentified
Outcome
Leave to represent the corporation refused; interlocutory application dismissed; costs awarded to the plaintiff.
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Court found the authority 'Checked Nominees Pty Ltd v ANZ Banking Group Ltd [1986] 4 ACLC 196' does not exist and was generated by the applicant's use of generative AI. || Fabricated: Case Law | Court found the authority 'Re Unique Building Services Pty Ltd [2012] ACTSC 104' does not exist and was generated by the applicant's use of generative AI.

Sanction teardown · ACT SC, Australia · 2026-04-21

Geha Enterprises Pty Ltd v Deuteronomy 28 Investments Pty Ltd and Registrar General of the ACT

What happened

In ACT SC, Australia, 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)
    Court found the authority 'Checked Nominees Pty Ltd v ANZ Banking Group Ltd [1986] 4 ACLC 196' does not exist and was generated by the applicant's use of generative AI.
  • Fabricated (Case Law)
    Court found the authority 'Re Unique Building Services Pty Ltd [2012] ACTSC 104' does not exist and was generated by the applicant's use of generative AI.

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

Leave to represent the corporation refused; interlocutory application dismissed; costs awarded to the plaintiff.

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/2566/Geha_Enterprises_Pty_Ltd_v_Deuteronomy_28_Investments_Pty_Ltd_21_April_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2566/Geha_Enterprises_Pty_Ltd_v_Deuteronomy_28_Investments_Pty_Ltd_21_April_2026.pdf

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