Incident Tracker / South Africa
FJL v TGO, Case No. 2025/220239 (Gauteng Division, Johannesburg, full court)
A full court of the High Court of South Africa, Gauteng Division, Johannesburg, upheld an acting judge's findings in a parenting dispute but identified at least eleven fictitious or garbled citations in his judgment, most plausibly AI hallucinations. Opperman J referred the acting judge to the Legal Practice Council, highlighting an accountability gap for acting judges.
- Court
- High Court of South Africa, Gauteng Division, Johannesburg (full court)
- Date
- 2026-07-31
- Who used the AI
- Judge
- AI tool
- Not identified in the record
- Conduct
- Acting Judge Themba Khaba's first-instance judgment in a schooling dispute cited a nonexistent case (Lubbe v Volkswagen SA), merged material from unrelated cases into a false S v Smith quotation, and miscited Mkhintha, Knoop v Gupta and Myeni, with at least 11 discrepancies the full court found most plausibly explained by AI hallucinations.
- Outcome
- Regulatory referral
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- Legal Practice Council (South Africa): Opperman J, in a separate concurrence, referred the acting judge to the Legal Practice Council, reasoning that acting judges remain practising advocates subject to the LPC rather than the Judicial Conduct Committee. No LPC disposition on record. (2026-07-31)
- Status
- Verified against listed sources
- Last checked
- 2026-09-03
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “FJL v TGO, Case No. 2025/220239 (Gauteng Division, Johannesburg, full court)”, safelegalai.com/tracker/fjl-v-tgo (accessed 2026-09-04). Data: CC BY 4.0.