The sanctions record · Australia, Victoria · court referral and regulator outcome
Dayal, and what the regulator actually did
Dayal [2024] FedCFamC2F 1166, Federal Circuit and Family Court of Australia · Victorian Legal Services Board variation of practising certificate, 19 August 2025 · Board statement published 2 September 2025
Page verified 5 August 2026. The regulator’s own published statement was read at source and is quoted below. The underlying judgment was not reachable from this session, so the court-side facts are recorded from the Board’s statement rather than quoted from the judgment.
The only matter anywhere in the world where the regulator published its own decision. Every other referral on this record ends at the referral, and the reader never learns what happened. Here the Victorian Legal Services Board set out exactly what it did, and it is heavier than most of the fines.
What the court found
The Board records the underlying conduct in one sentence: in Dayal [2024] FedCFamC2F 1166, the practitioner “tendered a list and summary of authorities to the court that had been generated through the use of artificial intelligence (AI) and provided inaccurate citations and summaries.” The Federal Circuit and Family Court of Australia referred him to the Board.
What the regulator did, in its own words
On 19 August 2025 the Board varied his practising certificate. The variation resulted in him:
- Principal“no longer being entitled to practise as a principal lawyer”
- Trust money“no longer being authorised to handle trust money”
- His practice“no longer operating his own law practice”
- Status“only practising as an employee solicitor”
- Supervision“undertaking supervised legal practice for a period of two years”
- Reporting“both the practitioner and his supervisor reporting to the Victorian Legal Services Board on a quarterly basis during the period of supervised legal practice”
“The Board’s regulatory action in this matter demonstrates our commitment to ensuring legal practitioners who choose to use AI in their legal practice do so in a responsible way that is consistent with their obligations.”
The Board closed by advising practitioners to read its Statement on the use of artificial intelligence in Australian legal practice, and, if they intend to use AI, to consider undertaking continuing professional development.
A correction to how this is being reported
Several outlets describe this as an Australian lawyer being “stripped of his licence”. He was not. He holds a practising certificate and may work as a lawyer. What he lost was the right to be a principal, to run his own firm and to touch trust money, for at least two years, under quarterly supervision reporting.
Other coverage attaches the Board’s decision to Valu v Minister for Immigration and Multicultural Affairs (No 2) [2025] FedCFamC2G 95. The Board’s own statement names Dayal [2024] FedCFamC2F 1166. Valu is a separate matter, also involving AI-generated non-existent citations. We have not opened that judgment and make no claim about its outcome.
Why the shape of this penalty matters more than its size
Compare it to the money. Whiting cost $15,000 each, paid once. This costs a lawyer his firm, his trust account and two years of professional autonomy, and it is visible to every client and every insurer for as long as it runs.
It is the answer to the partner who has priced this risk as a fine. The fine is the cheap outcome. The regulator is the expensive one, and it arrives months later, when the file is cold and nobody remembers what was checked.
What to do about it
Seven days free, then $349 a month.
A regulator asks its questions long after the work, of a practitioner who now has to reconstruct what happened. Two years of supervised practice turns on the quality of that reconstruction. A signed record of which AI you used and what a person checked, sealed to the exact file you deliver, made on your own machine and checkable free by anyone you send it to.
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For a firm rather than a practitioner, the same engine runs across the estate: Regulayer for enterprise. See also the attorney certification and every jurisdiction we track.
Sources
- Victorian Legal Services Board + Commissioner, “Statement on the ‘Mr Dayal’ matter”, 2 September 2025, read in full and quoted above
- Underlying judgment: Dayal [2024] FedCFamC2F 1166, Federal Circuit and Family Court of Australia. Not opened from this session; AustLII refused the connection. The court-side facts above are as stated by the Board.
- Separate Australian matter, not described here: Valu v Minister for Immigration and Multicultural Affairs (No 2) [2025] FedCFamC2G 95
Related
- The full sanctions record
- Australia: NSW Practice Note SC Gen 23, the rule side
- Ayinde v Haringey, where referrals were made but outcomes unpublished
Checked 5 August 2026 against the Board’s own statement. Information, not legal advice, and not advice on Australian practice.
Common questions
Who was the first Australian lawyer sanctioned for using AI?
A Victorian solicitor identified by the Federal Circuit and Family Court only as 'Mr Dayal', in Dayal [2024] FedCFamC2F 1166. He tendered to the court a list and summary of authorities generated using artificial intelligence which contained inaccurate citations and summaries. On 19 August 2025 the Victorian Legal Services Board varied his practising certificate.
What sanction did the Victorian Legal Services Board impose?
Six restrictions. He is no longer entitled to practise as a principal lawyer, no longer authorised to handle trust money, no longer operating his own law practice, may practise only as an employee solicitor, must undertake supervised legal practice for two years, and both he and his supervisor must report to the Board quarterly during that period.
Was Mr Dayal struck off?
No. He retains a practising certificate and can continue to work as a lawyer, but as a supervised employee rather than as a principal running his own practice. Reporting that described him as stripped of his licence is inaccurate.
Is there other Australian case law on lawyers using AI?
Yes. Valu v Minister for Immigration and Multicultural Affairs (No 2) [2025] FedCFamC2G 95 also involved AI-generated non-existent citations and fabricated quotes from a tribunal decision, with the practitioner admitting he had not verified the contents. We have not opened that judgment and do not describe its outcome here.
What does an Australian regulator expect of lawyers using AI?
The Board's statement points practitioners to its own Statement on the use of artificial intelligence in Australian legal practice, and strongly advises anyone intending to use AI in the course of legal practice to consider undertaking continuing professional development to improve their knowledge.
Information, not legal advice, and not advice on the law of any jurisdiction. Every entry is verified against the issuing body’s own document; where a source is reporting rather than the document, we say so.