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AI incident #1184 ·

Purported Fictitious AI-Generated Citations in Supreme Court of Victoria Murder Case Filing Lead to Delay and King's Counsel Apology

Open on the AI Incident Database 1 news report Snapshot 7 Sep 2026

What happened

Australian defense lawyer Rishi Nathwani KC reportedly filed submissions in a Supreme Court of Victoria murder case that included allegedly fictitious quotes and nonexistent case citations purportedly generated by AI. The errors were reportedly discovered by the judge's associates, causing a 24-hour delay in the proceedings. Nathwani apologized in court, taking full responsibility, while Justice James Elliott criticized the incident and reiterated that AI outputs must be independently verified.

Only the incident metadata is stored here. The underlying news reports are on the AI Incident Database (CC BY-SA 4.0); use the links above to read them.

News reports (1)

Coverage catalogued by the AI Incident Database. Titles link to the original publisher; the text is not reproduced here.

  1. Australian lawyer apologizes for AI-generated errors in murder case
    apnews.com · Rod McGuirk · AIID #6133

Who was involved

Alleged deployer
Rishi Nathwani
Alleged developer
Generative Ai Developers
Alleged harmed party
Accused Minor In Victoria State Murder Case, Rishi Nathwani, Daniel Porceddu, James Elliott, Supreme Court Of Victoria, Judicial Integrity

Classification (MIT AI Risk Repository taxonomy)

Risk domain
Misinformation
Causal entity
Human
Intent
Unintentional
Timing
Post-deployment
Harm level
—
Sectors
—
Countries
—

Risk entries describing this failure mode

Entries from the MIT AI Risk Repository coded to subdomain 3.1.

  • Pursuing Consistent Context

    "LLMs have been demonstrated to pursue consistent context [129]–[132], which may lead to erroneous generation when the prefixes contain false information. Typical examples include sycophancy [129], [130], false demonstra...

    Risk Taxonomy, Mitigation, and Assessment Benchmarks of Large Language Model Systems (Cui2024)

  • Knowledge Gaps

    "Since the training corpora of LLMs can not contain all possible world knowledge [114]–[119], and it is challenging for LLMs to grasp the long-tail knowledge within their training data [120], [121], LLMs inherently posse...

    Risk Taxonomy, Mitigation, and Assessment Benchmarks of Large Language Model Systems (Cui2024)

  • Hallucinations

    "LLMs generate nonsensical, untruthful, and factual incorrect content"

    Risk Taxonomy, Mitigation, and Assessment Benchmarks of Large Language Model Systems (Cui2024)

  • Faithfulness Errors

    "The LLM-generated content could contain inaccurate information" which is is not true to the source material or input used

    Risk Taxonomy, Mitigation, and Assessment Benchmarks of Large Language Model Systems (Cui2024)

  • Defective Decoding Process

    In general, LLMs employ the Transformer architecture [32] and generate content in an autoregressive manner, where the prediction of the next token is conditioned on the previously generated token sequence. Such a scheme...

    Risk Taxonomy, Mitigation, and Assessment Benchmarks of Large Language Model Systems (Cui2024)

  • Untruthful Content

    "The LLM-generated content could contain inaccurate information"

    Risk Taxonomy, Mitigation, and Assessment Benchmarks of Large Language Model Systems (Cui2024)

  • Factuality Errors

    "The LLM-generated content could contain inaccurate information" which is factually incorrect

    Risk Taxonomy, Mitigation, and Assessment Benchmarks of Large Language Model Systems (Cui2024)

  • Noisy Training Data

    "Another important source of hallucinations is the noise in training data, which introduces errors in the knowledge stored in model parameters [111]–[113]. Generally, the training data inherently harbors misinformation....

    Risk Taxonomy, Mitigation, and Assessment Benchmarks of Large Language Model Systems (Cui2024)

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