Alberta Law Student's AI-Drafted Appeal Backfires With Hallucinated Case Citation
An Edmonton articling student faces a sterner disciplinary rebuke after using artificial intelligence to draft an appeal of his law society suspension, then citing a case that did not exist.
Manraj Tiwana admitted to the Law Society of Alberta that he used AI to write his appeal submissions. The tool generated a fake case citation that he included in his arguments.
A seven-member appeal panel rejected his appeal in March and rebuked him for the misuse. "While we appreciate that Mr. Tiwana was candid in admitting his use of AI, he did not seem to grasp the gravity of misusing it in this way," the panel wrote.
The Original Suspension
Tiwana was suspended for 20 months in 2025 after the law society found he had taken clients without informing his articling supervisor. He accepted payment directly from those clients while keeping his principal in the dark about the arrangement.
During the investigation, Tiwana repeatedly misled investigators, according to the panel. He pleaded guilty to six disciplinary charges and initially accepted the 20-month suspension - described by the hearing panel as "as lengthy as it gets short of disbarment." The law society also ordered him to pay $18,000 in costs.
The Flawed Appeal
Tiwana later appealed the suspension, arguing it was too harsh. Representing himself this time, he submitted written arguments that cited a case the law society could not locate.
When a law society lawyer contacted him about the missing citation, Tiwana initially called it a "placeholder." The panel found it had been fabricated by an unspecified AI tool.
Beyond the hallucinated case, Tiwana repeatedly referenced a Law Society of British Columbia decision "which had no relevance at all to this matter," the panel said. When asked to provide the case's citation and legal name, "Mr. Tiwana struggled to understand what that meant."
The panel also rejected Tiwana's claim that he did not understand the consequences of a 20-month suspension. "These submissions, when made by a party represented before the hearing committee by experienced defence counsel, are difficult to accept," the panel wrote, referring to his earlier legal representation during the guilty plea.
Costs and Conduct
The panel upheld the original 20-month suspension and ordered Tiwana to pay the full costs of the appeal hearing. The panel cited his "haphazard approach" to presenting evidence and his conduct during the appeal as the primary factors in the cost decision.
The panel characterized Tiwana's overall conduct as displaying "abject dishonesty" and "long-running" attempts to deceive investigators.
Tiwana is not listed in the provincial lawyer directory. Attempts to reach him were unsuccessful.
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