Reddy v Saroya, 2025 ABCA 322
In Alberta, the Court of Appeal held counsel responsible for a contractor-drafted factum containing seven nonexistent authorities. Its September 2025 judgment invited submissions on personal costs against lead counsel. The reported January 2026 costs order remains unconfirmed against its primary text; no amount from that later report is recorded here.
- Court
- Court of Appeal of Alberta
- Date
- 2025-09-26
- Who used the AI
- Lawyer
- AI tool
- Not identified in the record
- Conduct
- An appellant's factum contained seven nonexistent authorities, six purportedly from the Alberta Court of Appeal. Lead counsel had retained a contractor and questioned the contractor's denial of large-language-model use after the errors emerged. The court held counsel responsible for verifying the filing and invited submissions on a possible personal costs award.
- Outcome
- Pending
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- 2026-09-21
What was fabricated or misused
- Seven nonexistent authorities in the appellant's original factum, six purportedly Alberta Court of Appeal decisions (paragraph 74)
Timeline
- Court of Appeal decision recorded seven non-existent authorities in the appellant's factum.
- Decision recorded counsel's account of outsourcing the factum and his doubts about the contractor's denial of large-language-model use.
- Decision signalled personal costs against the lawyer whose name appeared on the filing.
Why this case matters
Reddy concerns counsel's responsibility for a contractor-drafted factum. The Court of Appeal rejected any suggestion that outsourcing moved the duty to verify authorities away from counsel. Paragraph 87 invited submissions on whether lead counsel should personally pay some or all of the respondent's appeal costs; it did not itself fix a personal award. The later reported 2026 ABCA 20 order still requires primary-text verification.
Practice note
A lawyer who signs a factum should verify every authority personally or supervise a recorded verification process before filing. Contractor work should be treated like associate or student work: citations checked in an official or recognised database, holdings matched to the proposition, and any uncertain authority removed before the document bears counsel's name.
Primary sources for this incident
- Reddy v Saroya, 2025 ABCA 322 (26 Sep 2025), paragraphs 73–87 — CanLII judgment PDF mirrored by Damien Charlotin
- Reddy v Saroya, 2025 ABCA 322 — CanLII; automated access blocked on 21 Sep 2026
- Leads from Damien Charlotin's AI Hallucination Cases Database (CC BY 4.0), damiencharlotin.com; each decision re-read and coded by SafeLegalAI
Related regulation records for this incident
- Gen AI Rules of Engagement for Canadian LawyersLaw Society of Alberta · CA
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Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “Reddy v Saroya, 2025 ABCA 322”, safelegalai.com/tracker/reddy-v-saroya (accessed 2026-10-07). Data: CC BY 4.0.