Reddy v Saroya
CA Alberta · Sep 26, 2025
What happened in this matter?
The Alberta Court of Appeal addressed the submission of fabricated case law generated by an LLM. While the Court allowed an amended factum, it affirmed that counsel is strictly responsible for verifying all AI-generated submissions. The Court reserved the decision on costs, warning that failure to maintain human-in-the-loop verification constitutes an abuse of process and may attract significant financial penalties.
- Why the court cared
- The Court reasoned that lawyers are professionally responsible for the accuracy of all filed documents, regardless of whether they are drafted by third-party contractors or assisted by AI. It emphasized that the 'human in the loop' requirement is mandatory under the Alberta Courts' October 2023 Notice to prevent abuse of process and maintain the integrity of the justice system.
- Why it matters now
- Outsourced drafting is your liability; verify every citation before filing or pay the costs.
Why this matter is tracked
Fabricated: Case Law | Appellant's initial factum contained seven cited cases that could not be found (six purportedly ABCA decisions); court found they were likely fabricated and traced to use of a large language model; amended factum was permitted and costs referred. Outcome: Adverse Costs Order. The appellant's original factum contained references to seven cases that could not be located (six allegedly decisions of this Court). Respondent flagged the issue; appellant's counsel ultimately acknowledged a contractor-drafted factum and that a large language model may have been used. The Court allowed an amended factum and reserved costs, warning that use of LLM without verification may attract costs, contempt proceedings, or Law Society referral.Monetary sanction was determined in a subsequent decision (available here).
Outsourced drafting is your liability; verify every citation before filing or pay the costs.
Record details
What the record establishes about AI use
The court explicitly references the use of a large language model.
Appellate review of a contempt finding and associated procedural issues, including the handling of an AI-generated factum containing fabricated citations.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
1 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Appellant's initial factum contained seven cited cases that could not be found (six purportedly ABCA decisions); court found they were likely fabricated and traced to use of a large language model; amended factum was permitted and costs referred.
Questions this record answers
- What happened in Reddy v Saroya?
- The Alberta Court of Appeal addressed the submission of fabricated case law generated by an LLM. While the Court allowed an amended factum, it affirmed that counsel is strictly responsible for verifying all AI-generated submissions. The Court reserved the decision on costs, warning that failure to maintain human-in-the-loop verification constitutes an abuse of process and may attract significant financial penalties.
- Why does Reddy v Saroya matter for legal AI risk?
- Outsourced drafting is your liability; verify every citation before filing or pay the costs.
- What does the public record establish about Reddy v Saroya?
- 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.
- Which source supports this Reddy v Saroya 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.