'Hallucinated' Case Materials: A Warning To Lawyers

This Judgment comes as a stark and clear warning to legal practitioners of their duties and responsibilities in this age of AI which in the words of Judge Sharp creates "risks as well as opportunities."

The Facts

The two cases had been referred and listed under the Divisional Court's Hamid jurisdiction, following the actual or suspected use of generative AI platforms by lawyers to create materials to be put before the court, without verifying the authenticity and accuracy of the information provided (typically a fake citation or quotation).

In the Ayinde case (Ayinde v Haringey & Al-Haroun v Qatar [2025] EWHC 1383), as part of their judicial review case, the barrister representing Mr. Ayinde, Ms. Forey, misstated Section 188(3) of the Housing Act 1996 and cited inexistent cases to substantiate her grounds. As for the citation of one of the cases mentioned therein, it was the citation reference to a different case which concerned a charity's liability to pay