Assemblies of God Gospel Church v. Registrar of Societies

What happened

Assemblies of God Gospel Church v. Registrar of Societies, Miscellaneous Civil Application No. 9407 of 2026, was an application for extension of time in the High Court of Tanzania. The applicant, the registered trustees of the Assemblies of God Gospel Church International, had obtained leave for judicial review and filed a review application, which was struck out for containing matters for which leave had not been sought. Out of time to begin again, the trustees applied for more time to seek fresh leave. The respondents included the Registrar of Societies, the Permanent Secretary of the Ministry of Home Affairs and the Attorney General.

At the hearing on July 8, the applicant's advocate, Johnson Johannes Kachenje, argued that the original leave was spent once the review application was struck out. He supported the point with two Court of Appeal decisions and quoted each: Mwanza Restaurant Workers Co-operative Societies v. Regional Commissioner of Mwanza, Civil Appeal No. 27 of 1999, and Sanai Murumbe and another v. Managing Director, Serengeti Safari Lodges Limited [1986] T.L.R. 45. The first was quoted as holding that leave "is not a floating or permanent permit."

What the court did

Principal Judge M.M. Siyani could not find either decision online or in the 1986 Tanganyika Law Reports; page 45 of that volume is the second page of a different case. He was concerned that the cases "might have been non-existent cases at best or worse ghost cases, which are a potential product of Artificial Intelligence (AI) hallucination." On August 4 he ordered the advocate to produce copies or show cause why disciplinary action should not follow under the Advocates (Professional Conduct and Etiquette) Regulations.

On August 11 the advocate could not produce them. He said he had searched further and contacted the Mwanza and Musoma registries, conceded that he had sourced the decisions online, accepted responsibility and denied bad faith. Counsel for the respondents agreed the cases did not exist and asked the court to forgive him.

The ruling held that the duty of candor under Rule 92 is absolute and does not depend on intention. The judge found that the advocate "deceived the Court by misstating facts and law when he cited and quoted non-existent and potentially AI-generated cases of the Court of Appeal" and was guilty of professional misconduct. The ruling did not find that AI was used; it described the cases as potentially AI-generated. Noting that an earlier High Court reminder, given without sanction where counsel cited six nonexistent cases, had not deterred repetition, the judge ordered:

• the two cases and their quotations expunged from the record;
• suspension from practice for six months under section 30(2)(a) of the Advocates Act;
• a signed written public apology to the court and the public, published in English and Swahili in a widely circulating daily newspaper, with proof to the Registrar, failing which the suspension extends by one month until publication;
• no order as to costs.

Where it stands

The suspension in Assemblies of God Gospel Church runs from the date of the ruling, September 3. The ruling read for this entry deals only with the citations; it does not decide the extension application, and that outcome was not located as of October 21, 2026. Nor was proof of the published apology located.

The Assemblies of God Gospel Church ruling drew on Ayinde v. Haringey, Mata v. Avianca and the Indian Supreme Court's decision in Pooja Ramesh Singh. From the last, the judge took the view that the judiciary should have zero tolerance for nonexistent or fake AI-generated cases, applied equally to bar and bench. He surveyed the sanctions imposed in those cases and concluded that, while sanctions vary, some sanction is the common thread.

The obligation it engaged

Clause 3 of the Standard, independent authority, is the clause the ruling turned on. The advocate put quotations in the mouth of the Court of Appeal, whose decisions bind the High Court, and the judge treated that as a misstatement of law whatever its source. Clause 4, checkability before adoption, follows: a reported citation to a named volume and page could be checked quickly, and the judge did so while writing the ruling.

The lesson for an expert witness concerns quotations from authoritative sources. An expert who quotes a standard, a regulation or a decision lends that source's authority to his own opinion. The Assemblies of God Gospel Church ruling treated an unverified quotation as a misstatement even without bad faith, and an expert should quote only text he has read in the source itself.

Sources

• High Court of Tanzania (copy hosted for the AI Hallucination Cases database) · September 3, 2026
  Ruling in Misc. Civil Application No. 9407 of 2026

What could not be confirmed

The ruling was read from an OCR text of a scanned PDF; quotations were checked against the OCR and corrected only for spacing artifacts and the OCR's reading of AI as Al. Press reports in The Chanzo and The Citizen were not located and are omitted. The ruling does not decide the extension application; that outcome and proof of the published apology were not located as of 2026-10-21. AI use was described as potential, not found.