Incident Tracker / United Kingdom
Huish v Commissioners for HMRC, [2026] UKFTT 129 (TC)
·First-tier Tribunal (Tax Chamber)·UKOther
Before the First-tier Tax Tribunal, self-represented appellant Robert Huish cited four non-existent authorities he had generated using AI while preparing his hearing materials. The tribunal attached no blame to him given his litigant-in-person status but recorded the fake case names to warn others, and allowed his appeal on its substantive merits.
- Court
- First-tier Tribunal (Tax Chamber)
- Date
- 2026-01-16
- Who used the AI
- Not recorded
- AI tool
- Not identified in the record
- Conduct
- A self-represented appellant cited four purported authorities (Collins, Harrison, Baxter and Hicks) said to have been decided in 2021; none existed. He confirmed to the tribunal that he had used AI to help prepare his hearing materials.
- Outcome
- Other
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- 2026-09-11
What was fabricated or misused
- Collins, Harrison, Baxter and Hicks — four alleged 2021 cases relied on by the appellant; the tribunal and HMRC confirmed they did not exist
What the court said
“For one of his arguments, the appellant relied upon four cases which he said had been decided in 2021 and supported his position namely, Collins, Harrison, Baxter and Hicks.”
“On reconvening we asked the appellant if he had used AI to assist in preparation for the hearing and he confirmed that he had done so.”
“We attach no blame to him, since he is a litigant in person but we have recorded the names so that others do not fall into the same trap.”
“We allow the appeals.”
Timeline
- HMRC issued three High Income Child Benefit Charge discovery assessments.
- Mr Huish sent letters challenging the child-benefit tax charges.
- Mr Huish filed his appeal with the First-tier Tribunal.
- The remote hearing paused while the tribunal and HMRC checked the four AI-sourced cases.
- The tribunal allowed the appeals on the protected-assessment issue.
Why this case matters
Huish is useful because the false authorities did not drive the outcome. The Tax Chamber paused the hearing, checked the four unfamiliar names with HMRC, recorded the warning, and then allowed the appeal on valid statutory grounds. Compared with Folarin, the same tribunal system treated a litigant in person differently from an adviser applicant: Huish received no blame, while Folarin's unverified use fed into a fitness finding. The record therefore separates harm control at the hearing from punitive or regulatory consequences.
Practice note
A litigant in person can avoid this problem by bringing a copy of every case relied on, not only a name supplied by AI. If the case cannot be found on Find Case Law, BAILII, Westlaw, Lexis or an official tribunal source, it should not be cited. A tribunal may pause to check authorities, but the safe course is to verify before the hearing.
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
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Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “Huish v Commissioners for HMRC, [2026] UKFTT 129 (TC)”, safelegalai.com/tracker/huish-v-hmrc (accessed 2026-09-16). Data: CC BY 4.0.