Reddy v Saroya
CA Alberta · Sep 26, 2025
- Jurisdiction
- international
- Court
- CA Alberta
- Record ID
- reddy-v-saroya-2025-09-26
- Observed outcome
- The Court allowed the appellant to file an amended factum and reserved the determination of costs related to the respondent's time spent identifying the fabricated citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
Outsourced drafting is your liability; verify every citation before filing or pay the costs.
Failure modes and consequences
- Fake Citations
- Contract
- Appellate
- Monetary
- AI attribution
- Admitted
- Recorded tool
- large language model
- Known monetary consequence
- Not recorded
- Procedural posture
- Appellate review of a contempt finding and associated procedural issues, including the handling of an AI-generated factum containing fabricated citations.
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 court explicitly references the use of a large language model.
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
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Escalate unresolved verification failures before filing and preserve the responsible reviewer's signoff record.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.