Re Walker
SC Victoria · Nov 24, 2025
What happened in this matter?
The Supreme Court of Victoria reprimanded a solicitor for filing submissions containing hallucinated case law generated by 'CourtAid' and 'ChatGPT'. The Court determined that the solicitor's failure to verify AI-generated output violated professional standards and the Court's specific AI guidelines, constituting unsatisfactory professional conduct.
- Why the court cared
- Misrepresented: Case Law | Two other authorities in the submissions were inaccurately cited or misnamed; the solicitor provided corrected names/copies for some but one corrected authority was irrelevant to the passing-over issue. || Fabricated: Case Law | Two authorities cited in the defendant's opening submissions could not be located; Supreme Court Library inquiries confirmed they did not exist and the solicitor said AI produced the references.
- Why it matters now
- Using legal-tech tools like CourtAid alongside ChatGPT does not excuse verification — reprimands follow regardless of tool pedigree.
Why this matter is tracked
In Re Walker [2025] VSC 714, the Supreme Court of Victoria addressed a solicitor's use of generative AI in preparing court submissions. The solicitor, Ms. Rizkallah, used 'CourtAid' and 'ChatGPT' to identify case law for a passing-over claim. These tools generated non-existent or hallucinated citations. The solicitor failed to verify the existence or relevance of these authorities before filing. The Court found this conduct constituted unsatisfactory professional conduct, as it violated the Court's May 2024 Guidelines on the responsible use of AI and fell below the standards of diligence expected of a competent practitioner. The Court exercised its inherent jurisdiction to impose a formal reprimand, noting the solicitor's genuine contrition and the fact that the hallucinated claims were not ultimately pressed at trial.
Using legal-tech tools like CourtAid alongside ChatGPT does not excuse verification — reprimands follow regardless of tool pedigree.
Record details
What the record establishes about AI use
The solicitor used CourtAid and ChatGPT.
Disciplinary matter heard within the Court's inherent jurisdiction during a probate proceeding.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
2 citation, quotation, or authority issues are recorded in the source dataset.
- Misrepresented: Case Law | Two other authorities in the submissions were inaccurately cited or misnamed; the solicitor provided corrected names/copies for some but one corrected authority was irrelevant to the passing-over issue.
- Fabricated: Case Law | Two authorities cited in the defendant's opening submissions could not be located; Supreme Court Library inquiries confirmed they did not exist and the solicitor said AI produced the references.
Questions this record answers
- What happened in Re Walker?
- The Supreme Court of Victoria reprimanded a solicitor for filing submissions containing hallucinated case law generated by 'CourtAid' and 'ChatGPT'. The Court determined that the solicitor's failure to verify AI-generated output violated professional standards and the Court's specific AI guidelines, constituting unsatisfactory professional conduct.
- Why does Re Walker matter for legal AI risk?
- Using legal-tech tools like CourtAid alongside ChatGPT does not excuse verification — reprimands follow regardless of tool pedigree.
- What does the public record establish about Re Walker?
- 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 Re Walker 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.