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A self-professed expert in migration law has been handed a personal costs order for his courtroom conduct, including the inappropriate use of generative artificial intelligence.
Gurdial Singh Ranji Singh, principal solicitor and director of Quantum Legal Advisory & Migration Consultants, was ordered to pay $9,600 in costs, partly for his use of generative artificial intelligence in judicial review and costs proceedings.
While Singh admitted that six authorities in the judicial review submissions and five authorities in the costs proceedings were hallucinations, he only did so after the Federal Circuit and Family Court of Australia (FCFCOA) (Division 2) sought clarification.
Judge Simone Bingham said it was “unacceptable” that court resources were used to fact-check a lawyer’s submissions.
“The court expects that a lawyer will use their expertise and ensure that the authorities relied upon in submissions do in fact exist and are not mere hallucination of a generative AI program.
“The court expects that a lawyer will maintain their professional duties and obligations when utilising generative AI,” she said.
In addition to breaching his duties to the court, Singh’s improper use of AI “compromised the effective administration of justice”.
He then failed to attend court on two occasions when the issue of costs was to be heard and potentially determined. He also failed to appear remotely or retain counsel to appear on his behalf.
Judge Bingham said it was “disrespectful and tantamount to treating the court, [his client] and [opposing] lawyers with contempt”.
The FCFCOA decided against referring Singh’s conduct to a legal regulator, citing his acknowledgement of AI misuse, his apologies, his remorse, and his undertaking of professional development on the responsible use of AI in legal practice.
The public reprimand of him being named in the FCFCOA’s reasons and personal costs orders were sufficient, Judge Bingham said.
Singh was also criticised for a number of other courtroom blunders, including his failure to certify whether his client’s amended application for judicial review had reasonable prospects of success, as required under section 4861 of the Migration Act.
There was also no retainer in writing, no file notes of conversations about the retainer, or any substantive discussion regarding the terms and extent of the legal work.
Judge Bingham said this was a “clear case in which a costs order must be made against the lawyer personally”.
Citation: Dey v Minister for Immigration and Citizenship (No 2) [2026] FedCFamC2G 1799.
