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Incident Tracker / Singapore

Tan Hai Peng Micheal and another v Tan Cheong Joo and another [2026] SGHC 49

·General Division of the High Court of the Republic of Singapore·SGCosts order

In this Singapore High Court (General Division) costs ruling, S Mohan J made personal costs orders of S$5,000 each against the counsel on record and his supervising solicitor for filing fictitious AI-generated citations — S$10,000 within a global S$180,000 award. Both practitioners were held responsible for verifying the authorities rather than relying on delegation.

Court
General Division of the High Court of the Republic of Singapore
Date
2026-03-06
Who used the AI
Not recorded
AI tool
ChatGPT
Conduct
Court submissions contained fictitious AI-generated authorities. The court held that citing fictitious authorities is sanctionable whether or not AI produced them: the counsel on record had a non-delegable duty to verify, and the supervising solicitor who reviewed the draft also failed. The workload and supervision defence was rejected, each practitioner held individually accountable.
Outcome
Costs order
Penalty
SGD 10,000
Regulatory outcome
No separate regulatory disposition recorded
Status
Verified against listed sources
Last checked
2026-09-21

What was fabricated or misused

  • Case A — neutral citation and case name individually corresponded to real cases, but paired together they did not exist; the court did not repeat the citation
  • Case B — both the case name and neutral citation were entirely fictitious; the court did not repeat the citation

What the court said

“The Relevant Paragraphs cited two “cases”, which I shall refer to as “Case A” and “Case B” respectively (collectively, the “Fictitious Authorities”).”
General Division of the High Court of the Republic of Singapore, [6]
“AI tools can only ever play the part of the handmaiden. The fundamental point remains that lawyers bear ultimate responsibility for ensuring that all materials placed before the court – including case authorities – are, without exception, true and accurate, and crucially, verified by them to be so.”
General Division of the High Court of the Republic of Singapore, [32]
“In doing so, he had a non-delegable duty to ensure that the submissions were complete, accurate, and properly verified. By appending his signature to the final version of the submissions that were filed and served, he thereby accepted personal responsibility for all material submitted to the court.”
General Division of the High Court of the Republic of Singapore, [44]
“Mr Goh and Mr Sidhu should each personally pay costs to the Claimants in the sum of $5,000, making it a total of $10,000, and I so order.”
General Division of the High Court of the Republic of Singapore, [66]

Timeline

  1. Defendants filed closing submissions citing Case A and Case B.
  2. Claimants’ reply submissions brought the Fictitious Authorities Issue to court.
  3. Mr Goh acknowledged the allegations and said another solicitor supplied the authorities.
  4. Mr Goh identified Mr Sidhu; Sidhu said a paralegal prepared the initial draft.
  5. Court sought further clarification and positions on personal costs.
  6. Mr Goh filed submissions on the Fictitious Authorities Issue.
  7. High Court ordered S$5,000 personal costs each against Mr Goh and Mr Sidhu.

Why this case matters

Tan Hai Peng is the Singapore counterpart to Tajudin but adds a supervision-chain finding. The court did not stop with counsel on record. It also made a personal costs order against the solicitor who reviewed work prepared by a paralegal and sent to counsel. Compared with JNE24 v Minister for Immigration, where one lawyer’s AI research drew costs and a regulator referral, this record fixes responsibility across the handoff from paralegal to supervising solicitor to counsel who signed the submissions.

Practice note

Do not let a paralegal or junior staff member supply authorities without solicitor review. The counsel signing submissions must check the bundle, locate each cited case, and remove any authority that cannot be found. A reviewing solicitor should record who checked the cases and whether any AI tool was used before the draft leaves the firm.

Primary sources for this incident

Related regulation records for this incident

Similar incidents on the record

  • 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…
  • Parker v Forsyth NNO and Others (1585/20) [2023] ZAGPRD 12023-06-29 · Regional Court, Johannesburg (Gauteng Regional Division) · Costs orderIn South Africa, the Johannesburg Regional Court found that the plaintiff's attorneys supplied opposing lawyers with fictitious ChatGPT authorities without verification. It found no intention to mislead the court and or…
  • Hancox v Sutherland and others [2026] EAT 1392026-09-17 · Employment Appeal Tribunal · WarningIn the UK Employment Appeal Tribunal, an appellant filed a 300-page ChatGPT skeleton argument without checking accuracy or procedural compliance. No reliance was placed on it at the hearing. The tribunal warned that sim…
  • State ex rel. Oklahoma Bar Association v. Reeves, 2026 OK 372026-05-27 · Supreme Court of Oklahoma · WarningThe Oklahoma Supreme Court publicly reprimanded attorney Matthew Reeves under reciprocal-discipline rules after he admitted using ChatGPT to fabricate five citations in federal filings in Johnson v. Dunn — conduct alrea…

Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Tan Hai Peng Micheal and another v Tan Cheong Joo and another [2026] SGHC 49”, safelegalai.com/tracker/tan-hai-peng-v-tan-cheong-joo (accessed 2026-10-07). Data: CC BY 4.0.

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