Health Care Complaints Commission v Campbell
NSW CAT · Jan 30, 2026
- Jurisdiction
- international
- Court
- NSW CAT
- Record ID
- health-care-complaints-commission-v-campbell-2026-01-30
- Observed outcome
- The Tribunal established multiple complaints of unsatisfactory professional conduct and professional misconduct, ordered the cancellation of the respondent's registration as a pharmacist, and prohibited the respondent from providing health services for three years.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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likely used generative AI to draft submissions containing fabricated case law, non-existent pinpoint citations, and repealed statutory provisions.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.
Outdated Advice: Repealed Law | Submission cited 's 3(3)(c) of the National Law' which the Tribunal noted has been repealed (outdated statutory provision).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.
AI hallucinates both case names and paragraph numbers; verify pinpoint cites, not just the case reference.
Failure modes and consequences
- Hallucinated_case_law
- Hallucinated_pinpoint_citations
- Outdated_statutory_authority
- Pro Se
- Fake Citations
- Misrepresented Authority
- AI attribution
- Implied
- Recorded tool
- Generative Artificial Intelligence
- Known monetary consequence
- Not recorded
- Procedural posture
- Disciplinary hearing before the NSW Civil and Administrative Tribunal (Occupational Division) resulting in the cancellation of the respondent's pharmacist registration.
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
Tribunal accepted the Commission's submission that the practitioner employed Generative Artificial Intelligence.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.