What was hallucinated

Fabricated: Case Law | Appellant cited 'Perrin v HMRC [2018] UKFTT 221 (TC)' in submissions; Tribunal found the citation was an AI‑hallucinated/incorrect authority and did not support the appellant's proposition. || Fabricated: Case Law | Appellant relied on 'Moulsdale t/a Moulsdale Properties v HMRC [2021] UKFTT 271 (TC)' as supporting cancellation of penalties; Tribunal held this citation formed part of AI‑generated authorities and did not support the asserted proposition. || Fabricated: Case Law | Appellant cited 'Hanuman Commercial Ltd v HMRC [2018] UKFTT 0565 (TC)' to argue no SDLT liability where no completion; Tribunal found the citation was incorrect/AI‑generated and did not support the appellant's contention. || Misrepresented: Case Law | Appellant cited 'Vardy Properties and another v HMRC [2012] UKFTT 564 (TC)'; Tribunal accepted the citation existed but held the case did not support the proposition advanced (misapplied authority). || Misrepresented: Case Law | Appellant cited 'Peter Jackson (Jewellers) Ltd v HMRC [2009] UKFTT 246 (TC)'; Tribunal found the citation was correct but did not support the appellant's asserted legal proposition (misapplied authority).

Sanction teardown · UKFTT (Tax Chamber), UK · 2026-05-06

Omar Rafique v The Commissioners for His Majesty's Revenue and Customs

What happened

In UKFTT (Tax Chamber), 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 (Case Law)

Appellant cited 'Perrin v HMRC [2018] UKFTT 221 (TC)' in submissions; Tribunal found the citation was an AI‑hallucinated/incorrect authority and did not support the appellant's proposition.
Fabricated (Case Law)

Appellant relied on 'Moulsdale t/a Moulsdale Properties v HMRC [2021] UKFTT 271 (TC)' as supporting cancellation of penalties; Tribunal held this citation formed part of AI‑generated authorities and did not support the asserted proposition.
Fabricated (Case Law)

Appellant cited 'Hanuman Commercial Ltd v HMRC [2018] UKFTT 0565 (TC)' to argue no SDLT liability where no completion; Tribunal found the citation was incorrect/AI‑generated and did not support the appellant's contention.
Misrepresented (Case Law)

Appellant cited 'Vardy Properties and another v HMRC [2012] UKFTT 564 (TC)'; Tribunal accepted the citation existed but held the case did not support the proposition advanced (misapplied authority).
Misrepresented (Case Law)

Appellant cited 'Peter Jackson (Jewellers) Ltd v HMRC [2009] UKFTT 246 (TC)'; Tribunal found the citation was correct but did not support the appellant's asserted legal proposition (misapplied authority).

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

Warning

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/2155/Omar_Rafique_v_The_Commissioners_for_HMRC-2026_UKFTT_673_TC.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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