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Incident Tracker / United Kingdom

Ayinde v London Borough of Haringey; Al-Haroun v Qatar National Bank

·High Court of England and Wales (Divisional Court)·UKRegulatory referral

The landmark England and Wales ruling on AI-fabricated citations: in joined cases, the Divisional Court invoked the Hamid jurisdiction over submissions containing non-existent authorities, referred a barrister to the BSB and solicitors to the SRA, and warned that the court's restraint on contempt should not be read as precedent.

Analysis
Ayinde and Al-Haroun: England's Divisional Court sets the rule on AI-fabricated citations
Court
High Court of England and Wales (Divisional Court)
Date
2025-06-06
Who used the AI
Not recorded
AI tool
Not identified in the record
Conduct
Submissions in two joined cases contained fabricated or misstated authorities apparently derived from generative AI; the Divisional Court used the Hamid jurisdiction to address the conduct of the lawyers involved.
Outcome
Regulatory referral
Penalty
No monetary penalty recorded
Regulatory outcome
BSB / SRA: Barrister referred to the Bar Standards Board; solicitors referred to the Solicitors Regulation Authority. The court found the contempt threshold capable of being met but did not initiate proceedings, warning that leniency should not be treated as precedent. (2025-06-06)
Status
Verified against listed sources
Last checked
2026-09-03

What was fabricated or misused

  • R (on the application of El Gendi) v Camden LBC [2020] EWHC 2435 (Admin) — no such case; neutral citation belongs to R (Preservation and Promotion of the Arts Ltd) v Greater Manchester Magistrates’ Court
  • R (on the application of Ibrahim) v Waltham Forest LBC [2019] EWHC 1873 (Admin) — no such case
  • R (on the application of H) v Ealing LBC [2021] EWHC 939 (Admin) — no such case
  • R (on the application of KN) v Barnet LBC [2020] EWHC 1066 (Admin) — no such case
  • R (on the application of Balogun) v LB Lambeth [2020] EWCA Civ 1442 — no such case
  • Al-Haroun schedule of references — eighteen of forty-five citations did not exist; many existing cases were misquoted, irrelevant, or did not support the cited propositions

What the court said

“The referrals arise out of the actual or suspected use by lawyers of generative artificial intelligence tools to produce written legal arguments or witness statements which are not then checked, so that false information (typically a fake citation or quotation) is put before the court.”
High Court of England and Wales (Divisional Court), [3]
“Where those duties are not complied with, the court’s powers include public admonition of the lawyer, the imposition of a costs order, the imposition of a wasted costs order, striking out a case, referral to a regulator, the initiation of contempt proceedings, and referral to the police.”
High Court of England and Wales (Divisional Court), [23]
“This court’s decision not to initiate contempt proceedings in respect of Ms Forey is not a precedent. Lawyers who do not comply with their professional obligations in this respect risk severe sanction.”
High Court of England and Wales (Divisional Court), [69]
“A lawyer is not entitled to rely on their lay client for the accuracy of citations of authority or quotations that are contained in documents put before the court by the lawyer.”
High Court of England and Wales (Divisional Court), [81]

Timeline

  1. Haringey’s solicitor wrote that five cases in Ayinde’s grounds could not be found.
  2. Defendant applied for wasted costs over five fake cases and the section 188(3) misstatement.
  3. Ritchie J heard the wasted costs application after the underlying judicial review had resolved.
  4. Ritchie J referred Ayinde to the Hamid judge; Dias J dismissed Al-Haroun’s application and referred it too.
  5. Divisional Court heard both Hamid referrals.
  6. Judgment referred Forey to the BSB and Amadigwe to the SRA, without starting contempt proceedings.

Why this case matters

Ayinde is the England and Wales framework case for lawyers, not litigants in person. Harber v HMRC had already shown that an unrepresented party could put AI-invented tribunal decisions before a court. Ayinde moved the problem into regulated practice and used the Hamid jurisdiction to ask whether chambers, law centres, and regulators had trained and supervised lawyers adequately. Its warning that the decision not to start contempt proceedings is not a precedent explains why later UK records, including PSA v NMC, cite Ayinde when a court faces AI-generated authorities.

Practice note

Any lawyer filing a pleading, witness statement, or skeleton argument should trace every case and quotation to an authoritative source before service: legislation.gov.uk, The National Archives, official law reports, BAILII, or a recognised legal publisher. Supervising solicitors cannot rely on counsel or clients for citation checks. A chambers or firm should make that verification a recorded step before a document goes to court.

Primary sources for this incident

Related regulation records for this incident

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Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Ayinde v London Borough of Haringey; Al-Haroun v Qatar National Bank”, safelegalai.com/tracker/ayinde-v-haringey (accessed 2026-09-16). Data: CC BY 4.0.

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