Body by Michael Pty Ltd and Industry Innovation and Science Australia
Administrative Review Tribunal · Jan 24, 2025
- Jurisdiction
- international
- Court
- Administrative Review Tribunal
- Record ID
- body-by-michael-pty-ltd-and-industry-innovation-and-science-australia-2025-01-24
- Observed outcome
- The applicant withdrew the fabricated case law citations prior to the hearing; the Tribunal issued a warning regarding the use of AI in legal submissions.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The Tribunal warned that using AI for legal research is unacceptable and problematic. While no formal sanction was imposed because the applicant withdrew the fabricated citations before the hearing, the Tribunal cautioned that such conduct risks misleading the court and may result in adverse inferences in future proceedings.
The Tribunal reasoned that citing non-existent case law is inherently misleading, regardless of intent. It stated that the Tribunal independently verifies all submissions, making the discovery of such fabrications inevitable. The Tribunal concluded that parties should rely on publicly available databases rather than AI to ensure the integrity of the evidentiary record and avoid adverse inferences.
Tribunals cross-check every citation — withdrawing fakes before hearing avoids adverse inferences but not the warning.
Failure modes and consequences
- Pro Se
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- Administrative
- Trial
- AI attribution
- Admitted
- Recorded tool
- ChatGPT
- Known monetary consequence
- Not recorded
- Procedural posture
- Administrative review of a tax decision regarding R&D tax offset eligibility.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The Tribunal explicitly identified the use of ChatGPT as the source of the problematic citations.
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Compare every quoted passage and pincite directly with the underlying opinion or filing.
- Confirm that each authority supports the stated proposition and has not been mischaracterized.
- Apply the same source-checking controls to ChatGPT output as to any other research input.