Sanction teardown · High Court, UK · 2025-06-06
Ayinde v. Haringey & Al-Haroun v. QNB
What happened
In High Court, 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:
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Fabricated (Case Law)Fabricated case cited; Court confirmed it does not exist.
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Fabricated (Case Law)Fabricated case cited; Court confirmed it does not exist.
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Fabricated (Case Law)Fabricated case cited; Court confirmed it does not exist.
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Fabricated (Case Law)Fabricated Court of Appeal authority cited; Court confirmed it does not exist.
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Misrepresented (Legal Norm)Statutory duty misrepresented: s.188(3) HA 1996 stated as requiring interim accommodation; Court noted the statute is discretionary ('may secure').
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Fabricated (Case Law)In a separate County Court matter, grounds of appeal and skeleton contained non-existent cases; alerted by the judge.
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Fabricated (Case Law)Judicial assistant’s schedule identified 18 non-existent authorities across claimant’s and solicitor’s witness statements.
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False Quotes (Case Law)Existing cases were quoted for passages that do not appear in them in claimant’s and solicitor’s statements.
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Misrepresented (Case Law)Existing authorities cited did not support the propositions advanced or were irrelevant to the application.
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Fabricated (Case Law)Fabricated authority attributed to Dias J herself among citations to the court.
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Fabricated (Case Law)Fabricated case cited: El Gendi; Court found no such case exists and that the neutral citation belonged to an unrelated case about business rates.
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
No contempt, but referral to professional bodies
Additional detail
This judgment, delivered on 6 June 2025 by the Divisional Court of the King's Bench Division, addresses two cases referred under the court's Hamid jurisdiction, which concerns the court's power to enforce duties lawyers owe to the court. Both cases involve lawyers submitting written arguments or evidence containing false information, specifically non-existent case citations, generated through the use of artificial intelligence without proper verification.The Court used this opportunity to issue broader guidance on the use of AI in legal practice, raising concerns about the competence, training, and supervision of lawyers.
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.
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Source: https://www.damiencharlotin.com/documents/466/Ayinde_v._Haringey__Al-Haroun_v._QNB_UK_6_June_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).