Sanction teardown · ADGM, UAE · 2025-12-18
Arabyads Holding Limited v. Gulrez Alam Marghoob Alam
What happened
In ADGM, UAE, 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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Fabricated (Case Law)Defence cited a non-existent authority as “Allied Dunbar [1985]”; court found the citation did not exist and arose from inadequate verification of AI-derived research.
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Fabricated (Case Law)Defence cited “Johnston v Moreton [2014] EWHC 1219 (Ch)”, which did not exist as cited; court found the reference was erroneous and not verifiable.
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Misrepresented (Case Law)Defence included an incorrect citation “Halifax Life Ltd v DLA Piper LLP [2008]” (year and report incorrect); court treated this as an inaccurate/misleading citation arising from poor verification.
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Misrepresented (Case Law)Defence cited an Indian citation (“Capgemini India v Krishnan [2018] SCC OnLine Del 10990”) where an English case was intended, indicating careless/misleading citation.
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Misrepresented (Case Law)Defence relied on Caparo v Dickman [1990] 2 AC 605 for a proposition the case did not support; court found the authority misapplied.
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Misrepresented (Case Law)Defence cited Re Lehman Brothers Int'l (Europe) [2010] EWCA Civ 917 for a proposition it did not establish; court concluded the case was misused to support an incorrect legal point.
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
Mon (monetary penalty: 282508 .)
Additional detail
MIO produced a prolix Defence containing multiple non-existent, miscited and misapplied authorities. The Court found AI-driven research produced hallucinatory results and that MIO failed adequately to verify authorities, amounting to reckless conduct warranting an indemnity costs order.
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/1204/Arabyads_Holding_v._Gulrez_Alam_Marghoob_Alam_UAE_10_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).