What was hallucinated

Fabricated: Case Law | Farnell 2 cited numerous authorities with wrong citations or names and included some cases that do not exist; court found several citations irrelevant and unsupported by the authorities cited. || Misrepresented: Case Law | Paralegal responsible for drafting Farnell 2 admitted part of the research used Google's AI 'Overview' feature and that AI-generated results were relied on without appreciation of limitations; court noted misuse of AI and required explanations. || Fabricated: Case Law | Claimant's solicitors identified 12 problematic citations; the bundle filed by IPS listed 6 items as 'No. Case Name (as cited)', indicating non-existent or fabricated citations.

Sanction teardown · High Court, UK · 2025-11-04

Choksi v IPS

What happened

In High Court, UK, a filing relied on Google AI Overview to help draft legal argument. The court identified the following problems with the citations in that filing:

Fabricated (Case Law)

Farnell 2 cited numerous authorities with wrong citations or names and included some cases that do not exist; court found several citations irrelevant and unsupported by the authorities cited.
Misrepresented (Case Law)

Paralegal responsible for drafting Farnell 2 admitted part of the research used Google's AI 'Overview' feature and that AI-generated results were relied on without appreciation of limitations; court noted misuse of AI and required explanations.
Fabricated (Case Law)

Claimant's solicitors identified 12 problematic citations; the bundle filed by IPS listed 6 items as 'No. Case Name (as cited)', indicating non-existent or fabricated citations.

Which AI tool

Google AI Overview. 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

Not specified in source record.

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/1069/Choksi_v._IPS_Law_UK_4_November_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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