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ARTICLE · 03 AUGUST 2026

Ghost Authorities: AI Hallucinations In The Courtroom

ENS
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A South African Labour Court has stayed disciplinary proceedings after discovering that the chairperson's ruling relied on AI-generated, fictitious case citations. The judgment examines whether blind reliance on artificial intelligence tools constitutes a failure to apply independent legal reasoning, and what consequences flow from submitting fabricated authorities to courts and tribunals.

South AfricaLitigation, Mediation & Arbitration
Hendrik Hugo
Hendrik Hugo
Thabang Poshodi
Thabang Poshodi
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In Molawa, Springkaan, Smith v Matjhabeng Local Municipality and Another,(“Molawa”) Judge Allen-Yaman J was confronted with a disciplinary chairperson’s ruling that cited case authorities which, upon scrutiny, simply did not exist.

The Molawa judgment is the latest, and among the most consequential,in a growing line of authority addressing the submission of AI-generated, fictitious case citations to courts and tribunals. The Molawa Judgment is a pointed reminder that the convenience of artificial intelligence cannot substitute for the irreplaceable duty of independent legal reasoning.

Background and procedural history

The applicants, three municipal employees of the Matjhabeng Local Municipality, were charged with misconduct on 12 March 2021. The disciplinary hearing was delayed by interlocutory disputes, ultimately resolved by agreement in review proceedings (Case No. JR1790/21) on 9 October 2024. Despite this resolution, the municipality took no further steps to prosecute the

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