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Health Care Complaints Commission v Campbell

Court
NSW CAT
Jurisdiction
Australia
Decided
2026-01-30
AI tool
Implied
Outcome
—
Monetary penalty
None reported

What was hallucinated

Outdated Advice: Repealed Law | Submission cited 's 3(3)(c) of the National Law' which the Tribunal noted has been repealed (outdated statutory provision). || Misrepresented: Case Law | Submission relied on 'Health Care Complaints Commission v Mitchell [2012] NSWCATOD 151 at [98]', which the Tribunal found did not appear to exist and the cited paragraph did not exist in the real Mitchell decision. || Misrepresented: Case Law | Submission cited 'Psychology Council of NSW v X [2020] NSWCATOD 156' which does not exist; Tribunal noted the citation corresponds to HCCC v Rakheja [2020] NSWCATOD 156 and there is no such 'Psychology Council of NSW v X' authority. || Fabricated: Case Law | Submission cited 'Health Care Complaints Commission v Istephan [2012] NSWDT 1 at [8]', a decision that does not exist; Tribunal noted the actual Istephan decision is [2017] NSWCATOD 15 and another relevant 2012 citation is Phung (No 1) [2012] NSWDT 1.

Sanction teardown · NSW CAT, Australia · 2026-01-30

Health Care Complaints Commission v Campbell

What happened

In NSW CAT, 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:

  • Outdated Advice (Repealed Law)
    Submission cited 's 3(3)(c) of the National Law' which the Tribunal noted has been repealed (outdated statutory provision).
  • Misrepresented (Case Law)
    Submission relied on 'Health Care Complaints Commission v Mitchell [2012] NSWCATOD 151 at [98]', which the Tribunal found did not appear to exist and the cited paragraph did not exist in the real Mitchell decision.
  • Misrepresented (Case Law)
    Submission cited 'Psychology Council of NSW v X [2020] NSWCATOD 156' which does not exist; Tribunal noted the citation corresponds to HCCC v Rakheja [2020] NSWCATOD 156 and there is no such 'Psychology Council of NSW v X' authority.
  • Fabricated (Case Law)
    Submission cited 'Health Care Complaints Commission v Istephan [2012] NSWDT 1 at [8]', a decision that does not exist; Tribunal noted the actual Istephan decision is [2017] NSWCATOD 15 and another relevant 2012 citation is Phung (No 1) [2012] NSWDT 1.

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.

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/1520/Health_Care_Complaints_Commission_v_Campbell_Australia_30_January_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1520/Health_Care_Complaints_Commission_v_Campbell_Australia_30_January_2026.pdf

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