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Incident Tracker / Canada

R. v. Chand, 2025 ONCJ 282

·Ontario Court of Justice·CAOther

In Ontario, Justice Kenkel of the Ontario Court of Justice rejected defence final submissions in R. v. Chand after finding a fictitious citation, unsupported criminal authorities and unrelated civil cases. He ordered defence counsel to prepare new submissions with hyperlinks and no generative-AI research.

Court
Ontario Court of Justice
Date
2025-05-26
Who used the AI
Not recorded
AI tool
Not identified in the record
Conduct
In a criminal trial, defence counsel filed written final submissions containing a fictitious citation, case law that did not support the points cited, and unrelated civil cases. The judge rejected the submissions and ordered counsel to prepare a new set without generative AI or AI-powered legal research software.
Outcome
Other
Penalty
No monetary penalty recorded
Regulatory outcome
No separate regulatory disposition recorded
Status
Verified against listed sources
Last checked
2026-09-22

What was fabricated or misused

  • One cited case appeared to be fictitious and could not be found at the cited place or anywhere else
  • Some cited cases did not support the points of law for which they were cited
  • Some cited cases were civil authorities unrelated to the criminal-law issues in the trial

What the court said

“One of the cases cited appears to be fictitious. The court was unable to find any case at that name or citation.”
Ontario Court of Justice, [2]
“Some of the case law relied upon by the defence does not support the point of law for which it is cited.”
Ontario Court of Justice, [3]
“I find it necessary to order that Mr. Ross personally prepare a new set of defence submissions”
Ontario Court of Justice, [5]
“generative AI or commercial legal software that uses GenAI must not be used for legal research for these submissions.”
Ontario Court of Justice, [5]

Timeline

  1. Ontario Court of Justice issued directions rejecting the defence final submissions and requiring counsel to prepare new submissions under specified citation rules.

Why this case matters

Chand is narrower than a sanctions order. Justice Kenkel did not make a final finding about which tool produced the errors and did not punish counsel, but he treated the submission defects as serious enough to require a fresh filing personally prepared by defence counsel. The order matters because it names practical controls: numbered paragraphs and pages, pinpoint citations, hyperlinks to CanLII or another source, and no generative-AI research for the replacement submissions.

Practice note

Criminal submissions should link every authority to CanLII or another reliable database and include pinpoint paragraphs for the proposition relied on. If a court identifies possible AI-style citation errors, the replacement filing should be rebuilt from verified authorities, not patched from the earlier document.

Primary sources for this incident

Related regulation records for this incident

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Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “R. v. Chand, 2025 ONCJ 282”, safelegalai.com/tracker/r-v-chand (accessed 2026-10-07). Data: CC BY 4.0.

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