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“I have used AI in the production of this decision… This decision has my name at the end. I am the decision-maker, and I am responsible for this material. The judgment applied - in the sense of the evaluative faculty, weighing-up the arguments, and framing the terms of the order - has been entirely mine.”

"The Divisional Court has provided guidance in the case of R (Ayinde) v London Borough of Haringey, Al-Haroun v Qatar National Bank QPSC [2025] EWHC 1383 (Admin) that the consequence of using AI large language models in a way which results in false authorities being cited is likely to be referral to a professional regulator, such as the BSB or SRA,  as it is a lawyer’s professional responsibility to ensure that checks on the accuracy of citation of authority or quotations are carried out using reputable sources of legal information. Where there is evidence of the deliberate placing of false material before the Court police investigation or contempt proceedings may also be appropriate"

The question I have is whether the AI hallucinations in law will ever stop, considered from the perspective of the technology rather than the lawyers. My view is that unless the technology itself stops producing them, AI hallucinations in law will remain a problem in legal work internationally.

"...This is the third distinct filing over a monthlong period in which Plaintiffs have used non-existent quotations to attempt to defeat Fenix’s requests for relief. ..This pattern of submitting false, AI-generated law is an “abuse of the judicial system” that harasses Fenix and wastes the Court’s time and resources..."

N.Z. et al. v. Fenix International Ltd

This case illustrates the practical challenges created when litigants rely on AI-generated legal content without adequate verification. The Tribunal carefully balanced the Respondent’s wasted costs against the Claimant’s honest but misguided use of AI, ultimately declining to award costs. The judgment reflects some tribunals’ willingness to treat such mistakes with leniency, while still recognising the additional burdens placed on opposing parties.

Welcome to Natural and Artificial Intelligence in Law. Natural and Artificial Intelligence in Law is a professional resource at the intersection of AI law, human rights, equality, housing and civil justice. Curated by barrister Matthew Lee and now enjoying an international readership, the blog offers expert commentary, practical guidance, and live trackers AI Law. Read all about the project here.

This post is an update to my earlier piece on The Real Dangers of AI Chatbots: Garcia v Character AI litigation. It reviews new developments in that case, highlights further alleged harms, and surveys related litigation and government action that point to what we may see next.

It appears there were around 45 alleged incidents of AI hallucinations and/or fabricated citations in August, only a slight reduction from the 50 or so reported in July. That figure may still change, as further incidents could emerge retrospectively in legal databases.

August is not yet over, and we have already seen around 30 alleged incidents of AI hallucinations and/or fabricated citations internationally. July alone recorded approximately 50 such incidents. I had initially hoped to review the cases monthly, but the sheer volume now requires a weekly update

"AI hallucinations are not a minor inconvenience. They are a professional risk that can catch out even the most experienced practitioners and judges. Sometimes this comes down to simple carelessness, but sometimes it is because of how convincing and subtle these errors can be, especially when we are working under the extreme pressures so common in this profession. That is why, as a profession, I believe we need to keep talking about them openly. We are all vulnerable. Even those who have told me, “I completely avoid AI,” cannot truly do so. It may appear in your instructions, in witness evidence, or in your opponent’s work, and you have a duty to recognise and address it."