SG | General Division of the High Court of the Republic of Singapore
Docket: HC/OC 747/2025 (HC/SUM 2841/2025; HC/SUM 2992/2025; HC/SUM 3072/2025) • first instance
2026-01-21
Forbes Monaco APAC v Kawajiri Seiji [2026] SGHC 16 — Grounds of Decision
Unspecified generative AI tool fake_case_citation; no_human_verification; misleading_filing; ai_attribution_excuse
I. Executive Summary
The General Division set aside an ex parte freezing order after finding the claimant’s case was “utterly without merit” and that the controller (a self-represented person) had dishonestly abused court process. In addressing misconduct, the court noted that the claimant’s filings included multiple fictitious legal authorities and rejected the explanation that they were merely an “internal practice draft generated with a generative‑AI tool” sent in error. The court ordered personal costs against the controller (instead of the claimant entity), including S$30,000 payable to the defendant.
II. Conduct Analysis
A self-represented controller advanced a civil claim and supporting materials that included fictitious case authorities; when confronted, he sought to downplay this by attributing the fictitious authorities to an internal draft produced with a “generative‑AI tool” that was mistakenly submitted. The court treated this as a contrived and dishonest excuse in the context of broader abuse of process and misrepresentations to the court.
III. Legal Foundations
Bouvier, Yves Charles Edgar v Accent Delight International Ltd [2015] 5 SLR 558 (freezing order test); Rules of Court 2021 (Order 56 r 1 referenced in standing analysis); costs order (personal costs)
IV. Key Facts
Decision date 21 January 2026 (Grounds of Decision). The court set aside the freezing order and described extensive misconduct, including citing fictitious legal authorities; the judgment records the party’s attempt to excuse the fictitious authorities as an internal draft generated with a generative‑AI tool. The court ordered personal costs against the controller, including S$30,000 payable to the defendant.
V. Consequences & Sanction
Freezing order set aside; personal costs ordered against the controller (not the claimant), including S$30,000 payable to the defendant.