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Saregama India Ltd. v. B.A., et al.

Court
S.D. New York
Jurisdiction
USA
Decided
2025-12-03
AI tool
Implied
Outcome
—
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Reply cited 'Khurana v. State of N.Y., No. 16-cv ... 2019 WL 1430202' — Court observed this cited case does not exist. || False Quotes: Case Law | Reply attributed quotations to F.I. duPont, Glore Forgan & Co. v. Chen that the Court found not to appear in that opinion (false quotation). || Misrepresented: Case Law | Reply cited Bossuk v. Steinberg and S.E.C. v. McNulty for propositions the Court found they do not support (misrepresentation of precedent). || Misrepresented: Legal Norm | Reply misquoted statutes including CPLR § 2103(f)(1) and Fed. R. Civ. P. 69(a)(1); Court noted statutory misquotations.

Sanction teardown · S.D. New York, USA · 2025-12-03

Saregama India Ltd. v. B.A., et al.

What happened

In S.D. New York, USA, 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)
    Reply cited 'Khurana v. State of N.Y., No. 16-cv ... 2019 WL 1430202' — Court observed this cited case does not exist.
  • False Quotes (Case Law)
    Reply attributed quotations to F.I. duPont, Glore Forgan & Co. v. Chen that the Court found not to appear in that opinion (false quotation).
  • Misrepresented (Case Law)
    Reply cited Bossuk v. Steinberg and S.E.C. v. McNulty for propositions the Court found they do not support (misrepresentation of precedent).
  • Misrepresented (Legal Norm)
    Reply misquoted statutes including CPLR § 2103(f)(1) and Fed. R. Civ. P. 69(a)(1); Court noted statutory misquotations.

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.

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Source: Damien Charlotin's public AI Hallucination Cases Database (CC0).

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