Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided July 24, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · King's Bench, UK · 2026-07-24

Lodhia v Twelve Trees

What happened

In King's Bench, UK, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

Fabricated (Exhibits & Submissions)

Doctored email purporting to be from the University Assessment Office (dated 20 April) stating criminal oral assessment on 6 May; court found the email was fabricated.
Fabricated (Exhibits & Submissions)

Fictitious addition 'Section 5A' to the University of Law Inclusion Plan converting assessments to oral format; exhibited in support of adjournment application and found to be fabricated.
Fabricated (Exhibits & Submissions)

Altered version of the court's 29 April Order sent to the University with material removals/changes; court found the order had been doctored.
Fabricated (Exhibits & Submissions)

Series of letters of claim (6/7 March) and accompanying certificates of service claimed to have been posted and served; court found the letters and backdated/false certificates were fabricated.
Fabricated (Exhibits & Submissions)

Formal N260 Statement of Costs (5 May 2026) claiming c£82,839.40 (including £10,000+VAT to counsel) and accompanying false declarations; court found the declaration false and unsupported.
Fabricated (Case Law)

Reference to a non-existent 'detailed judgment' of Master Dagnall relied upon in correspondence; court found the judgment did not exist and the reference was misleading.

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Costs Order; 3-year General Civil Restraint Order; Bar Referral

Additional detail

The claimant (litigant in person) produced multiple fabricated or doctored documents which he later said were AI-generated 'hallucinations'. Examples included a doctored University Assessment Office email, a fabricated Section 5A addition to his ULIP, an altered copy of Steyn J's 29 April Order, fabricated letters of claim with false certificates of service, and a false N260 statement of costs claiming ~£82,800. The court rejected the AI excuse as insufficient, found the documents and several witness statements to be false/manipulated, and treated this as serious misconduct. The court ordered indemnity costs, ordered payment of the costs of the 6 May hearing, made a 3-year General Civil Restraint Order, referred the matter to the Attorney General for possible contempt (and police referral), and referred the barrister/JSC Chambers to the Bar Standards Board for investigation into supervision and regulatory compliance. (Summary by GPT 5.1)

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/2888/Lodhia_UK_24_July_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).