Singapore Courts: Cases of AI Fabrication a “Misuse of Technology”

This article was first published on 23 November 2025 in the Singapore Mandarin broadsheet, Lianhe Zaobao.

SLW obtained permission to reproduce the article to give the legal community a broader view of legal reports for various news syndicates.

In response to two recent incidents involving the submission of fictitious cases and authorities created with the use of generative AI by lawyers, the Singapore Courts have reiterated that lawyers bear full personal responsibility for the content of their submissions and that the filing of fictitious authorities is wholly impermissible under the courts’ guidelines.

Responding to enquiries by Lianhe Zaobao, a spokesperson for the Singapore Courts referred to the Guide on the Use of Generative Artificial Intelligence Tools by Court Users, which states that submitting fabricated or fictitious cases is “deemed a severe abuse of process and is wholly impermissible” and constitutes a “clear misuse of technology.”

The two cases highlighted the risk of AI hallucination and the importance of a lawyer’s obligation to independently verify any material generated by AI tools.

The judgment for the first case, which involved lawyer Lalwani Anil Mangan of DL Law Corporation, was issued in September this year. High Court Assistant Registrar Tan Yu Qing ordered Lalwani to personally pay the Defendant costs in the sum of $800, being the costs of and incidental to his citation of the Fictitious Authority.

Lalwani claimed the fabricated case was generated by his junior lawyer but conceded that he was wholly responsible for verifying the content. The Assistant Registrar emphasised that it is impermissible to cite a hallucinated case, and that his conduct was improper. The Assistant Registrar gave no weight to Mr Lalwani’s attribution of the fictitious citation to the error of the alleged junior lawyer, noting that there was no evidence of the same adduced before the Court.

The second incident happened in a loan recovery case. In his closing submissions, the defendant’s lawyer Goh Peck San from P S Goh & Co cited two AI-generated cases that were non-existent, which was subsequently discovered by the claimant’s lawyer. During the hearing, Justice S Mohan asked counsel to explain what had happened.

Goh said he had engaged another lawyer, Amarjit Singh Sidhu from Amarjit Sidhu Law to assist with research, but did not know that an AI tool was used. Sidhu said it was an honest oversight – there had been no intention to mislead the court, and he apologised to the court and the lawyers on both sides, and especially to Goh Peck San. Justice Mohan will issue his decision after the two lawyers provide further details.

In response to queries, the Law Society of Singapore (LSS) said it was unable to comment on the incidents as one of the cases is still ongoing, adding that “disciplinary matters are confidential.”

LSS stressed that all practising lawyers are bound by the Legal Profession (Professional Conduct) Rules 2015, are expected to act with integrity at all times, and must use AI responsibly and ethically. The Society noted that “the administration of justice depends on the professionalism of lawyers in exercising due diligence and professional judgment to verify that all submissions are properly supported before filing them”, whether or not they use AI tools.

It further stated that lawyers “must therefore ensure the authenticity and accuracy of legal authorities that are placed before the court as they have a paramount duty to the Court.”

LSS also reminded lawyers of their duty to protect client confidentiality, noting that they “should avoid uploading client confidential data into AI tools when searching for legal cases.”

To help lawyers deal with the opportunities and risks of AI, LSS said it will continue to make available useful resources and has conducted conferences, webinars and workshops on Generative AI. It has also established a Generative AI Committee to study the challenges posed by AI and will consider issuing advisories.

LSS added that it is “open to exploring working with other stakeholders to further increase the profession’s awareness of the responsible use of AI.”

With regard to misuse, the Singapore Courts issued the Guide on the Use of Generative AI Tools by Court Users in October last year, clarifying the usage guidelines and reinforcing the professional obligations of lawyers. The Guide requires lawyers to take full responsibility for all content, including AI-generated material, and states that all AI output must be independently verified, accurate, true and appropriate.

According to the spokesperson, when the Court detects fabricated or unverified AI material in submissions, the matter may be dealt with within the court process. For example, the presiding judge or judicial officer hearing the case may request counsel who submitted the material to ascertain the facts, describe the research process and explain how the material was derived to determine the degree of wrongdoing, whether it was improper, unreasonable, or negligent conduct. The Court “may also refer the matter to the Law Society of Singapore for potential investigation into professional misconduct under the Legal Profession Act.”

As set out in the Guide, lawyers who submit fictitious or forged cases may face consequences such as personal liability for cost, disregard of the submitted material and disciplinary action.

The spokesperson added that as the technology evolves and new patterns of misuse emerge, the Courts will continue to actively monitor, review and refine the existing guidance and judicial responses, which the emphasis remains on personal accountability and independent verification by the lawyer.

“We aim to give space for the proper use of AI, which holds great promise for increased efficiency and effectiveness, while reducing the risk and effect of abuse. We will respond more strongly if current measures do not appear sufficient.”

This article first appeared in Lianhe Zaobao.

Source: Lianhe Zaobao © SPH Media Limited. Permission required for reproduction.

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