Registerd Trustees of AGGCI vs Registrar of Societies & 5 Others - PM Ruling

Registered Trustees of AGGCI v Registrar of Societies & 5 Others, Misc. Civil Application No. 9407 of 2026

Facts:
The Applicant sought an extension of time in judicial-review proceedings after an earlier application had been struck out. In arguing the application, counsel relied on two purported Court of Appeal authorities. The Court was unable to trace the decisions and discovered that one of the cited TLR pages corresponded to an entirely different case. Counsel was required to explain the citations, could not produce the authorities, and ultimately accepted responsibility, describing the incident as an unfortunate professional mistake. The Court also considered the possibility that the authorities were generated through AI hallucination.

Issues:

1. The applicant required fresh leave following the striking out of the earlier judicial-review proceedings; and
2. Citing non-existent judicial authorities constituted professional misconduct, particularly where counsel claimed there was no intention to mislead and where AI may have been involved.

Holding:
The Court held that an advocate has a strict professional duty to verify authorities placed before the Court. Lack of bad faith or intention to deceive does not absolve an advocate who presents a non-existent authority as genuine. The responsibility remains with the advocate even where the information was obtained online or generated by technology. The Court treated the conduct as professional misconduct and imposed a six-month suspension, together with a requirement for a public apology; failure to publish the apology attracted a further month of suspension.

Jurisprudential Value & Novelty

- AI and professional responsibility: It is an important Tanzanian authority connecting AI-generated or potentially AI-generated legal authorities with advocates' professional obligations and integrity .
- Verification is mandatory: It establishes a strong objective standard an advocate must exercise the skill, prudence and diligence expected of a reasonable lawyer when citing authorities.
-“AI made the mistake” is not a defence: Responsibility for material submitted to Court remains with counsel.

-Actual disciplinary consequence:  The six-month suspension demonstrates that fabricated or non-existent authorities can attract serious professional sanctions rather than merely judicial criticism.

Critical Foundation

The decision is a formal warning in as much as it lays a precedent. Its professional and jurisprudential significance is nevertheless substantial, particularly as Tanzania develops its emerging jurisprudence on AI, legal research, professional ethics and judicial integrity.