The sanctions record · Federal Court of Canada, 2026
Ahmed v. Canada (Citizenship and Immigration)
Shumon Ahmed, Shamima Sorkar and Abdullah Sadat Bin Ahme v. The Minister of Citizenship and Immigration, 2026 FC 1202, IMM-3886-26 · Reasons and Judgment, Justice Lafrenière, Ottawa · 28 September 2026 · motion in writing under Rule 369
Page verified 1 October 2026. Reasons and judgment read in full, twenty-six paragraphs; every quotation is from them. Source: the decision as published on CanLII, obtained as a PDF from the AI Hallucination Cases document store because CanLII refuses automated retrieval.
The document, not the delay, decided it. The applicants’ record was filed fifteen days late because of a staff error, which the court would not hold against them. What it would not accept was the content: five cited cases that “cannot be found at the citations provided”, and real cases cited for propositions they do not contain. With no reply to explain them, the court concluded that AI had been used “without careful human judgment being applied to the output”, refused the extension of time and dismissed the application for leave and judicial review. No costs were ordered, because the Minister did not ask for them. No referral.
The record
- CourtFederal Court of Canada
- JudgeJustice Roger R. Lafrenière
- CaseIMM-3886-26, a motion to extend the time to file the applicants’ record in a judicial review of a Refugee Protection Division decision finding a refugee claim manifestly unfounded
- Date28 September 2026
- ToolAI, not named. Inferred by the court from the citations and the absence of any reply
- False citationsFive cases not found at the citations given: Kazi, 2015 FC 1140; Lopez Velasco, 2011 FC 1290; Olarewaju, 2003 FC 1294; Saint-Vil, 2018 FC 644; Yuan, 2018 FC 155. Real cases cited for what they do not say: He, 2019 FC 2; Garza, 2018 FC 155, where “There are as well no paragraphs 28 through 33”; Sitnikova, 2017 FC 1082
- OutcomeExtension of time refused; application for leave and judicial review dismissed
- AmountNone. The court said the applicants were exposed to sanctions including substantial costs, but none were ordered because the Minister did not seek them
- DisciplineNo referral
What the court found
The Minister opposed the extension on one ground only: the record had no merit to admit, because it cited cases that do not exist and cases for propositions they do not contain. The applicants had the chance to reply under Rule 369(3) and did not. The court treated the citations as a matter of integrity, not form:
“Citing fake cases in court filings is an abuse of process and is tantamount to making a false statement to the Court.”
It separated the two failures in the file. The missed deadline was the legal assistant’s miscalculation, and an error of counsel “should not be visited on the Applicants”. But “the critical concern here is not the mere inadvertence of the legal assistant in calculating the filing date of the Applicants’ Record, it is the content of the document itself.”
“AI tools promise efficiency; however, their indiscriminate use in drafting legal arguments constitutes a pernicious threat to the integrity of the judicial process. Fabricated case citations distort and corrupt the case law.”
“Whether accidental or deliberate, reliance on false citations and advancing misleading arguments on matters of substance cannot be condoned by this Court.” The court added that, on a full reading of the tribunal’s decision, the applicants’ criticisms did not undermine it.
Why it matters
The consequence fell on the case. There was no fine and no referral. The court refused to admit the document, and with it went the clients’ application for judicial review. The court also pointed to the next step open to an opposing party: removal of an abusive document from the court file under Rule 74, the remedy granted in Lloyd’s Register Canada Ltd v Choi, 2025 FC 1233.
It is now a line of authority in one court. The judgment cites Djatsa, 2026 FC 729, Sinkova, 2026 FC 650, and Lloyd’s Register, and the Federal Court’s practice notice already requires a declaration where AI generated content in a filed document. Hussein v. Canada is the same court on concealed reliance on AI.
The lesson for the next filing
The applicants were invited to explain how the citations came to be, and nothing was offered. Only a record of what had been checked, by whom and when, could have answered the question the court asked.
Regulayer™ creates checkable evidence of who approved exact words and when: which AI was used, what a named person reviewed, and the document it was sealed to, made at the time and verifiable free by the court without trusting the person who made it. It does not do the checking. It shows that the checking happened, and who stood behind it.
Sources
- Ahmed v. Canada (Citizenship and Immigration), 2026 FC 1202 (28 September 2026), reasons and judgment as published on CanLII, eleven pages, read in full for this page from Damien Charlotin’s AI Hallucination Cases document store
Related
- The full sanctions record
- Hussein v. Canada, the Federal Court on concealed reliance on AI
- Zhang v. Chen, cited in this judgment for fake citations as an abuse of process
- Canada, the courts’ AI practice directions
Verified 1 October 2026 against the reasons and judgment, read in full. Information, not legal advice.
Information, not legal advice. Every entry is verified against the court’s own document or contemporaneous reporting; where a source is reporting rather than the document, we say so.