# AI-fabricated quotes and nonexistent citations in a Supreme Court of Victoria murder case

> Defence King's Counsel Rishi Nathwani apologised to Justice James Elliott after filing submissions containing AI-generated fabrications — fake quotes from a legislature speech and nonexistent case citations — in a Melbourne murder proceeding. The errors caused a 24-hour delay; no monetary sanction was reported.

- Verification status: verified
- Case type: deployment
- Provider: Supreme Court of Victoria, Melbourne — Elliott, J.
- Client: Murder proceeding before Elliott J. (defence: Rishi Nathwani KC and Amelia Beech), Court proceeding — generative-AI hallucinated legal citations (named)
- Sector: legal / AU / cross
- Verified on: 2026-08-27
- Canonical URL: https://theinternetninja.com/stories/scv-elliott-nathwani-ai-fabricated-parliamentary-quotes-citations-murder-mental-impairment-2025/
- Source: The Internet Ninja (theinternetninja.com), independent verified-proof platform

## Verification method

Tier-1 primary obtained: Elliott J.'s written reasons, Director of Public Prosecutions v GR [2025] VSC 490 (14 Aug 2025), publicly indexed on AustLII under the accused's pseudonym and archived on Wayback, state the fabrications, counsel of record, the judge's rebuke and the verdict first-hand. Two independent Tier-2 secondaries (AP wire via NBC News; Lawyers Weekly) corroborate, naming the parties, the court and the judge, and carry the 24-hour delay. Quotes checked mechanically against stored captures.

## Full case file

## The problem

In a murder proceeding in the Supreme Court of Victoria in Melbourne, before Justice James
Elliott, the defence team filed written submissions that contained generative-AI fabrications —
"fabricated quotes from a speech to the state legislature and nonexistent case citations
purportedly from the Supreme Court" ([source](https://www.nbcnews.com/world/australia/australian-lawyer-sorry-ai-errors-murder-case-fake-quotes-made-cases-rcna225220))
[Source 1, Tier 2]. Justice Elliott's associates could not find the cited cases and asked the
defence lawyers to provide copies; the cases did not exist [Source 1, Tier 2].

The court's own written reasons record the same first-hand. Elliott J.'s catchwords list
"Misinformation produced by artificial intelligence" ([source](https://www.austlii.edu.au/cgi-bin/viewdoc/au/cases/vic/VSC/2025/490.html)),
"Hallucinated case references" and "Accuracy of quotations and citations not verified" [Source 3,
Tier 1], and note that the revised submissions "removed fictitious quotes from what were
previously said to be parts of the Second Reading Speech" ([source](https://www.austlii.edu.au/cgi-bin/viewdoc/au/cases/vic/VSC/2025/490.html))
[Source 3, Tier 1]. Counsel of record are stated as "R Nathwani KC with A Beech" ([source](https://www.austlii.edu.au/cgi-bin/viewdoc/au/cases/vic/VSC/2025/490.html))
[Source 3, Tier 1].

## What happened

This is a court-origin AI-hallucination record, not a technology deployment: the defence
submissions were prepared with the assistance of generative AI and filed without adequate
checking. Per Lawyers Weekly, the defence team — "senior barrister Rishi Nathwani KC and junior
Amelia Beech" — "failed to properly check the submissions before filing" ([source](https://www.lawyersweekly.com.au/biglaw/42801-judge-rips-lawyers-for-submitting-ai-generated-blunders-in-murder-trial))
[Source 2, Tier 2]. The documents held "references to non-existent case citations and inaccurate
parliamentary quotes" ([source](https://www.lawyersweekly.com.au/biglaw/42801-judge-rips-lawyers-for-submitting-ai-generated-blunders-in-murder-trial))
and were "unsigned by both barristers and solicitors" [Source 2, Tier 2], and even the re-filed
corrected submissions "still contained further inaccuracies, including references to non-existent
legislation and appeals" ([source](https://www.lawyersweekly.com.au/biglaw/42801-judge-rips-lawyers-for-submitting-ai-generated-blunders-in-murder-trial))
[Source 2, Tier 2].

## The outcome

King's Counsel Rishi Nathwani took full responsibility and told the court, "We are deeply sorry
and embarrassed for what occurred" ([source](https://www.nbcnews.com/world/australia/australian-lawyer-sorry-ai-errors-murder-case-fake-quotes-made-cases-rcna225220))
[Source 1, Tier 2]. Justice Elliott stated, "At the risk of understatement, the manner in which
these events have unfolded is unsatisfactory" ([source](https://www.nbcnews.com/world/australia/australian-lawyer-sorry-ai-errors-murder-case-fake-quotes-made-cases-rcna225220)),
and that "It is not acceptable for artificial intelligence to be used unless the product of that
use is independently and thoroughly verified" ([source](https://www.nbcnews.com/world/australia/australian-lawyer-sorry-ai-errors-murder-case-fake-quotes-made-cases-rcna225220))
[Source 1, Tier 2].

The errors "caused a 24-hour delay" ([source](https://www.nbcnews.com/world/australia/australian-lawyer-sorry-ai-errors-murder-case-fake-quotes-made-cases-rcna225220))
in resolving a case Elliott had hoped to conclude a day earlier [Source 1, Tier 2]. On Thursday
14 August 2025, Elliott ruled that the accused — a 16-year-old who cannot be identified because he
is a minor — was "not guilty of murder because of mental impairment" ([source](https://www.nbcnews.com/world/australia/australian-lawyer-sorry-ai-errors-murder-case-fake-quotes-made-cases-rcna225220))
over the April 2023 death of a 41-year-old woman in Abbotsford [Source 1, Tier 2]. No fine or
formal professional-conduct referral is reported in the reachable sources.

## Weakest link (source honesty)

The two turning-point facts — the AI fabrications and Justice Elliott's rebuke — each rest first
on a Tier-1 record: Elliott J.'s own published reasons, *Director of Public Prosecutions v GR*
[2025] VSC 490 [Source 3]. The weakest load-bearing source is the **AP wire report as carried by
NBC News** [Source 1]: it is an independent Tier-2 newsroom, not the primary court document, and
it is the only source that carries the "24-hour delay" figure and the verbatim in-court quotes.
Those quotes are corroborated in substance by the second independent newsroom (Lawyers Weekly)
and by the court's own reasons, but the exact "24-hour" number appears in that single wire report.

## How this was verified

**Method:** Justice Elliott's written reasons — *Director of Public Prosecutions v GR* [2025] VSC
490 (14 Aug 2025) — were obtained from AustLII, where the judgment is publicly indexed under the
accused's pseudonym ("GR"), and archived on the Wayback Machine; they state the fabrication
findings, counsel of record, the judge's rebuke and the verdict as a first-party court artifact
(Tier 1). Two independent Tier-2 newsrooms corroborate every critical claim: the Associated Press
wire report (via NBC News, 15 Aug 2025) and Lawyers Weekly (19 Aug 2025), both naming the parties,
the court and the judge. Every quoted line was checked mechanically against the stored captures.
**Date:** 8 August 2026. This is a documentary honest-negative — a public court record of an AI
failure, not a client outcome — so it carries no positive outcomes and never a green client badge.
A war-room green would still require the human verification step: confirming, against the primary,
the exact count of fabricated citations and quotes and whether any costs order or conduct referral
followed. This story can never be set to `verified` by any agent.

## Related case files

- [Prososki v. Regan — Nebraska Supreme Court strikes an AI-fabricated brief](/stories/prososki-v-regan-nebraska-supreme-court-lake-ai-fictitious-citations-brief-struck-appeal-dismissed-discipline-referral-2026/) — an appellate court dismissing an appeal and referring counsel for discipline over fictitious AI citations.
- [Ringo v. Colquhoun — Oregon Court of Appeals, $2,000 in sanctions](/stories/ringo-v-colquhoun-oregon-appeals-watson-2000-ai-fabricated-citations-500-per-cite-1000-per-quote-2025/) — a per-citation and per-quote sanction schedule for AI-fabricated authorities.
- [Torres-Campos v. Muñoz — California Court of Appeal, $5,000 sanction](/stories/torres-campos-v-munoz-cal-app-4th-buchanan-5000-ai-fabricated-citations-dog-custody-2026/) — a US appellate court imposing a monetary sanction where Victoria imposed none.
- [Smith v. Farwell — Massachusetts Superior Court, $2,000 sanction](/stories/smith-v-farwell-mass-super-davis-2000-ai-fabricated-citations-2024/) — an early trial-court sanction in the same AI-hallucinated-citation pattern.

## Sources

1. NBC News (Associated Press) · *Australian lawyer apologizes for AI errors in murder case as fake quotes made up cases* · 15 August 2025 · Tier 2 · https://www.nbcnews.com/world/australia/australian-lawyer-sorry-ai-errors-murder-case-fake-quotes-made-cases-rcna225220
2. Lawyers Weekly · *Judge rips lawyers for submitting AI-generated blunders in murder trial* · 19 August 2025 · Tier 2 · https://www.lawyersweekly.com.au/biglaw/42801-judge-rips-lawyers-for-submitting-ai-generated-blunders-in-murder-trial
3. AustLII — Supreme Court of Victoria · *Director of Public Prosecutions v GR [2025] VSC 490* · 14 August 2025 · Tier 1 · https://www.austlii.edu.au/cgi-bin/viewdoc/au/cases/vic/VSC/2025/490.html