When Columho is in the classroom, someone asks him if he ever "made up" evidence that didn't exist. ironically, in that same episode, he does JUST that!! When he creates the airline ticket to Phoenix that never really existed. Wonder if that was put in there as a spoof....
Columbo did not make up or create any evidence which was going to be presented in court during the trial. I believe that was the nature of the question asked of him by the student.