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PS v London Borough of Wandsworth

Court
Upper Tribunal
Jurisdiction
UK
Decided
2025-07-14
AI tool
Implied
Outcome
—
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Appellant cited 'R (L) v Devon County Council [2011] UKUT 192 (AAC)', which the Tribunal found does not exist; judge noted it may be an AI-generated fabrication. || Misrepresented: Case Law | Appellant cited 'R (C) v London Borough of Sutton [2010] UKUT 184 (AAC)'; Tribunal noted the neutral citation is valid but the title/subject the appellants gave is incorrect (case relates to child support), so the reference was misattributed. || Misrepresented: Legal Norm | Appellant relied on paragraph 9.169 of the SEND Code of Practice 2015 as supporting a requirement for parental consent to 'off-rolling'; Tribunal found that paragraph does not say that and the citation was inaccurate. || Misrepresented: Case Law | Appellant attributed a passage to B and M v Cheshire East Council [2018] UKUT 232 (AAC) (citing [25]) that the Tribunal found the case does not contain; the case exists but the quoted passage is not present.

Sanction teardown · Upper Tribunal, UK · 2025-07-14

PS v London Borough of Wandsworth

What happened

In Upper Tribunal, 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 'R (L) v Devon County Council [2011] UKUT 192 (AAC)', which the Tribunal found does not exist; judge noted it may be an AI-generated fabrication.
  • Misrepresented (Case Law)
    Appellant cited 'R (C) v London Borough of Sutton [2010] UKUT 184 (AAC)'; Tribunal noted the neutral citation is valid but the title/subject the appellants gave is incorrect (case relates to child support), so the reference was misattributed.
  • Misrepresented (Legal Norm)
    Appellant relied on paragraph 9.169 of the SEND Code of Practice 2015 as supporting a requirement for parental consent to 'off-rolling'; Tribunal found that paragraph does not say that and the citation was inaccurate.
  • Misrepresented (Case Law)
    Appellant attributed a passage to B and M v Cheshire East Council [2018] UKUT 232 (AAC) (citing [25]) that the Tribunal found the case does not contain; the case exists but the quoted passage is not present.

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

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.

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

Source: https://www.damiencharlotin.com/documents/1272/PS_v._Wandsworth_UK_11_July_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1272/PS_v._Wandsworth_UK_11_July_2025.pdf

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