Health Care Complaints Commission v Campbell
NSW CAT · Jan 30, 2026
What happened in this matter?
The Tribunal found that the respondent pharmacist likely used generative AI to draft submissions containing fabricated case law, non-existent pinpoint citations, and repealed statutory provisions. The Tribunal explicitly identified these errors as evidence of AI-generated content, noting the submissions were of limited utility due to these inaccuracies.
- Why the court cared
- Outdated Advice: Repealed Law | Submission cited 's 3(3)(c) of the National Law' which the Tribunal noted has been repealed (outdated statutory provision). || Misrepresented: Case Law | Submission relied on 'Health Care Complaints Commission v Mitchell [2012] NSWCATOD 151 at [98]', which the Tribunal found did not appear to exist and the cited paragraph did not exist in the real Mitchell decision. || Misrepresented: Case Law | Submission cited 'Psychology Council of NSW v X [2020] NSWCATOD 156' which does not exist; Tribunal noted the citation corresponds to HCCC v Rakheja [2020] NSWCATOD 156 and there is no such 'Psychology Council of NSW v X' authority. || Fabricated: Case Law | Submission cited 'Health Care Complaints Commission v Istephan [2012] NSWDT 1 at [8]', a decision that does not exist; Tribunal noted the actual Istephan decision is [2017] NSWCATOD 15 and another relevant 2012 citation is Phung (No 1) [2012] NSWDT 1.
- Why it matters now
- AI hallucinates both case names and paragraph numbers; verify pinpoint cites, not just the case reference.
Why this matter is tracked
In a professional disciplinary proceeding before the New South Wales Civil and Administrative Tribunal, the respondent pharmacist submitted legal arguments that included fabricated case law and outdated statutory references. The Tribunal determined that the respondent likely utilized generative artificial intelligence to draft these submissions. Specifically, the respondent cited a non-existent case, 'Health Care Complaints Commission v Istephan [2012] NSWDT 1', and misrepresented the content and existence of other authorities, such as 'Health Care Complaints Commission v Mitchell [2012] NSWCATOD 151'. Additionally, the respondent relied on a repealed section of the National Law. The Tribunal noted these submissions were of limited utility and accepted the Commission's assertion regarding the use of AI in their creation.
AI hallucinates both case names and paragraph numbers; verify pinpoint cites, not just the case reference.
Record details
What the record establishes about AI use
Tribunal accepted the Commission's submission that the practitioner employed Generative Artificial Intelligence.
Disciplinary hearing before the NSW Civil and Administrative Tribunal (Occupational Division) resulting in the cancellation of the respondent's pharmacist registration.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
4 citation, quotation, or authority issues are recorded in the source dataset.
- Outdated Advice: Repealed Law | Submission cited 's 3(3)(c) of the National Law' which the Tribunal noted has been repealed (outdated statutory provision).
- Misrepresented: Case Law | Submission relied on 'Health Care Complaints Commission v Mitchell [2012] NSWCATOD 151 at [98]', which the Tribunal found did not appear to exist and the cited paragraph did not exist in the real Mitchell decision.
- Misrepresented: Case Law | Submission cited 'Psychology Council of NSW v X [2020] NSWCATOD 156' which does not exist; Tribunal noted the citation corresponds to HCCC v Rakheja [2020] NSWCATOD 156 and there is no such 'Psychology Council of NSW v X' authority.
- Fabricated: Case Law | Submission cited 'Health Care Complaints Commission v Istephan [2012] NSWDT 1 at [8]', a decision that does not exist; Tribunal noted the actual Istephan decision is [2017] NSWCATOD 15 and another relevant 2012 citation is Phung (No 1) [2012] NSWDT 1.
Questions this record answers
- What happened in Health Care Complaints Commission v Campbell?
- The Tribunal found that the respondent pharmacist likely used generative AI to draft submissions containing fabricated case law, non-existent pinpoint citations, and repealed statutory provisions. The Tribunal explicitly identified these errors as evidence of AI-generated content, noting the submissions were of limited utility due to these inaccuracies.
- Why does Health Care Complaints Commission v Campbell matter for legal AI risk?
- AI hallucinates both case names and paragraph numbers; verify pinpoint cites, not just the case reference.
- What does the public record establish about Health Care Complaints Commission v Campbell?
- Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
- Which source supports this Health Care Complaints Commission v Campbell summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.