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Incident Tracker / Canada

Reddy v Saroya, 2025 ABCA 322

·Court of Appeal of Alberta·CACosts order

In Reddy v Saroya, the Court of Appeal of Alberta held that an appellant's factum containing seven fabricated authorities — produced by a contractor using generative AI — was the signing lawyer's responsibility. It signalled personal costs; a later order (reported as 2026 ABCA 20, CAD $17,550) is said to be Canada's first personal-costs order for AI hallucinations.

Court
Court of Appeal of Alberta
Date
2025-09-26
Who used the AI
Not recorded
AI tool
generative AI (unnamed)
Conduct
An appellant's factum contained seven non-existent authorities, six purportedly from the Alberta Court of Appeal, produced by a contractor the lawyer had hired who used generative AI. The Court held that the lawyer whose name appears on a filing bears ultimate responsibility for its contents, even where a contractor drafts it.
Outcome
Costs order
Penalty
No monetary penalty recorded
Regulatory outcome
No separate regulatory disposition recorded
Status
Verified against listed sources
Last checked
Not separately recorded

What was fabricated or misused

  • Seven non-existent authorities in the appellant's factum, six said to be Alberta Court of Appeal decisions; the judgment was not fetchable here, so the case names could not be verified from primary text

Timeline

  1. Court of Appeal decision recorded seven non-existent authorities in the appellant's factum.
  2. Decision attributed the authorities to a contractor who used generative AI.
  3. Decision signalled personal costs against the lawyer whose name appeared on the filing.

Why this case matters

Reddy adds a Canadian responsibility rule that differs from Zhang v Chen. Zhang involved counsel's direct ChatGPT use in a family case; Reddy involved a contractor hired by counsel. The record matters because the Court of Appeal treated the signing lawyer's name on the factum as the control point. Delegating drafting did not move the duty to verify authorities away from counsel. The later reported personal-costs order also moved the matter from warning to financial consequence, a step that Canadian courts had considered in earlier AI-citation cases.

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

Related regulation records for this incident

Similar incidents on the record

  • Arbuckle v. Tanner, 2026 NSCA 622026-08-12 · Nova Scotia Court of Appeal (chambers) · Costs orderThe Nova Scotia Court of Appeal dismissed a family-law appeal for failure to perfect it and ordered lump-sum costs of CAD 20,000 after the self-represented appellant filed AI-generated transcripts containing invented te…
  • Hussein v. Canada (Immigration, Refugees and Citizenship), 2025 FC 1060; 2025 FC 11382025-06-24 · Federal Court of Canada · Costs orderIn Canada's Federal Court, applicant's counsel used Visto.ai in an immigration matter and filed submissions relying on non-existent cases without declaring the AI use. Associate Judge Catharine Moore found the conduct c…
  • Zhang v Chen, 2024 BCSC 2852024-02-20 · Supreme Court of British Columbia · Costs orderThe first reported Canadian case of AI-hallucinated citations: a Vancouver family lawyer cited two ChatGPT-invented cases in a notice of application, was ordered to pay costs personally, had her other files reviewed, an…
  • A.P. v. S.K. (Droit de la famille, 261234), 2026 QCCA 10922026-08-11 · Quebec Court of Appeal · SanctionsThe Quebec Court of Appeal ordered a self-represented family-law appellant to pay CAD 1,000 under article 342 of the Code of Civil Procedure after he conceded that four cited judgments, including two attributed to the S…

Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Reddy v Saroya, 2025 ABCA 322”, safelegalai.com/tracker/reddy-v-saroya (accessed 2026-09-16). Data: CC BY 4.0.

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