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."

"So, how pervasive is the problem? Is it growing, or are we counting loudly reported outliers? Let's look at each year and focus on the position before Ayinde v London Borough of Haringey and Al-Haroun v Qatar National Bank [2025] EWHC 1383 (Admin) ("Ayinde") and what has happened since. "

“While [attorney] has not admitted to using AI to prepare the briefing in this case, we find that to be a reasonable conclusion based upon our review of the briefing, the response to the rule to show cause, and [attorney] past conduct. We emphasize it is not the use of AI itself that is concerning; rather, it is the apparent failure to thoroughly review the work-product therefrom before submitting it to this court. See id. ¶ 131”