Geha Enterprises Pty Ltd v Deuteronomy 28 Investments Pty Ltd and Registrar General of the ACT
ACT SC · Apr 21, 2026
- Jurisdiction
- international
- Court
- ACT SC
- Record ID
- geha-enterprises-pty-ltd-v-deuteronomy-28-investments-pty-ltd-and-registrar-general-of-the-2026-04-21
- Observed outcome
- Application for leave to represent the corporation dismissed; costs awarded to the plaintiff.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The ACT Supreme Court refused to grant leave for a corporate director to represent his company after he submitted written arguments containing two fabricated legal authorities generated by AI. The court dismissed the application and ordered the defendant to pay the plaintiff's costs.
The court reasoned that the applicant's use of generative AI to produce non-existent legal authorities demonstrated a lack of professional rigor, undermining his claim that his legal qualifications justified an exception to the rule requiring corporate legal representation.
This case illustrates the risks of using generative AI for legal research without verification. The court explicitly cited the submission of fabricated authorities as a factor in denying the applicant's request to represent his corporation, highlighting the impact of AI-generated hallucinations on judicial credibility assessments.
Failure modes and consequences
- Pro Se
- Fake Citations
- Trial
- Monetary
- Case Dismissed
- AI attribution
- Admitted
- Recorded tool
- Unidentified generative artificial intelligence software
- Known monetary consequence
- Not recorded
- Procedural posture
- Interlocutory application for leave to represent a corporation dismissed by the Supreme Court of the ACT.
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 applicant conceded the use of generative artificial intelligence software.
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
- Implement mandatory verification protocols for all case law citations generated or assisted by AI tools.
- Ensure that any party seeking leave to represent a corporation understands the court's expectation of professional standards and duty to the court.
- Review all AI-assisted filings for accuracy and existence of cited authorities prior to submission.