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Shahin v Industrial Relations Secretary on behalf of Multicultural NSW (No.2)

Court
Industrial Relations Commission (NSW)
Jurisdiction
Australia
Decided
2026-07-21
AI tool
Unidentified
Outcome
Adverse Inferences
Monetary penalty
None reported

What was hallucinated

Misrepresented: Legal Norm | Appellant relied on AI-assisted material that imported the Fair Work Act concept of a 'valid reason' (s 387(a)) into proceedings under the IR Act, reflecting a misapplication of statutory law. || Misrepresented: Exhibits & Submissions | AI-assisted evidence/submissions contained inaccurate or inconsistent factual assertions (notably about post-dismissal income and mitigation) which the appellant attributed to his use of AI; Commissioner treated this as failure to ensure truth and accuracy of evidentiary material.

Details

The Full Bench noted the appellant admitted using generative AI to prepare evidence and submissions and failed to verify the truth and accuracy of AI-produced material. The Court found the appellant advanced arguments derived from an inapplicable statutory regime (invoking the Fair Work Act concept of a 'valid reason') and produced inconsistent evidence about mitigation and income, which he attributed to AI use. The Bench criticised this misuse under Practice Note 33, drew adverse inferences about credibility and accuracy, and refused leave to appeal. No professional discipline or monetary penalty was ordered.

Sanction teardown · Industrial Relations Commission (NSW), Australia · 2026-07-21

Shahin v Industrial Relations Secretary on behalf of Multicultural NSW (No.2)

What happened

In Industrial Relations Commission (NSW), 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:

  • Misrepresented (Legal Norm)
    Appellant relied on AI-assisted material that imported the Fair Work Act concept of a 'valid reason' (s 387(a)) into proceedings under the IR Act, reflecting a misapplication of statutory law.
  • Misrepresented (Exhibits & Submissions)
    AI-assisted evidence/submissions contained inaccurate or inconsistent factual assertions (notably about post-dismissal income and mitigation) which the appellant attributed to his use of AI; Commissioner treated this as failure to ensure truth and accuracy of evidentiary material.

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

Adverse Inferences

Additional detail

The Full Bench noted the appellant admitted using generative AI to prepare evidence and submissions and failed to verify the truth and accuracy of AI-produced material. The Court found the appellant advanced arguments derived from an inapplicable statutory regime (invoking the Fair Work Act concept of a 'valid reason') and produced inconsistent evidence about mitigation and income, which he attributed to AI use. The Bench criticised this misuse under Practice Note 33, drew adverse inferences about credibility and accuracy, and refused leave to appeal. No professional discipline or monetary penalty was ordered.

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: https://www.damiencharlotin.com/documents/2989/Shahin_v_Industrial_Relations_Secretary_No.2_2026_NSWIRComm_11_21_July_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2989/Shahin_v_Industrial_Relations_Secretary_No.2_2026_NSWIRComm_11_21_July_2026.pdf

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