Incident Tracker / United Kingdom
Lodhia v Twelve Trees, [2026] EWHC 1889 (KB)
·High Court of England and Wales, King's Bench Division (Media and Communications List)·UKCosts order
Linden J in the High Court of England and Wales found that a litigant in person had fabricated or doctored documents and rejected his claim that they were AI hallucinations. The court imposed indemnity costs and a three-year civil restraint order, and referred him to the Attorney General and his barrister to the Bar Standards Board.
- Court
- High Court of England and Wales, King's Bench Division (Media and Communications List)
- Date
- 2026-07-24
- Who used the AI
- Litigant in person
- AI tool
- Not identified in the record
- Conduct
- Litigant in person Amar Lodhia produced doctored or fabricated documents, including a university email, a fictitious 'Section 5A' inclusion-plan clause, an altered court order, false certificates of service and a false N260 costs statement claiming about GBP 82,800, and blamed AI hallucinations. Linden J rejected that explanation and certified several applications as totally without merit.
- Outcome
- Costs order
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- Bar Standards Board: Linden J referred direct-access counsel Mr Chiffers of JSC Chambers to the BSB. The litigant himself was referred to the Attorney General for possible contempt proceedings, with a police referral. No BSB disposition on record. (2026-07-24)
- Status
- Verified against listed sources
- Last checked
- 2026-09-08
What was fabricated or misused
- 20 April 2026 University of Law Assessment Office email — doctored to show a 6 May criminal-law oral assessment and a 7 May contract-law oral assessment
- ULIP “Section 5A – Oral Assessment Adjustments: Contract Law and Criminal Law (Added 24 April 2026)” — fabricated section saying both assessments had been converted to oral format
- 10th and 11th witness statements — false evidence that the assessments clashed with the 6–7 May hearing and that the criminal-law assessment had been rescheduled
- 29 April 2026 order of Steyn J — Word version sent to Ms Verrell removed reasons, removed references to the fake ULIP and inserted a made-up paragraph
- Draft witness statement for Ms Verrell — asked her to confirm a false assessment timetable and unexplained rescheduling
- 6 and 7 March 2025 letters of claim and N215 certificates — court found fabricated letters and false certificates, with case numbers that post-dated the alleged service
- Begbies Traynor 30 April 2025, 29 November 2025 and 11 December 2025 letters — misdated, altered or unauthorised versions used to claim trustee permission and no exposure to adverse costs
- Master Dagnall “judgment” in QB-2022-000089 at a 13 August 2025 hearing — no judgment existed; only a later order and a minute were produced
- 5 May 2026 N260 Statement of Costs — false declaration that Mr Lodhia was liable for about £82,800, including £10,000 plus VAT to Mr Chiffers
What the court said
“Mr Lodhia relied on fabricated or doctored documents and submitted witness statements containing false evidence to support his application. He then doctored an order of the court – the 29 April Order – and he subsequently gave false evidence to the court, in witness statements verified with statements of truth, seeking to explain his actions.”
“I am quite prepared to accept that Mr Lodhia used AI to create documents but what required to be explained is how the AI tool came to be generating documents which painted a false picture, and doctoring others, without any prompting to do so by Mr Lodhia.”
“I am therefore satisfied that the declaration which Mr Lodhia made in the 5 May statement of costs was false in the respects identified above and that his subsequent witness statements which have sought to support and explain it are also false. He was not liable to pay any of the sums claimed.”
“In the light of my findings about the conduct of Mr Lodhia, I have concluded that this matter should be referred to the Attorney General’s Office for consideration of whether to proceed against him for contempt of court and/or to refer the matter to the police.”
Timeline
- Claim dated 25 March sought defamation and malicious-falsehood damages
- Steyn J listed summary disposal and meaning hearings
- Lodhia sent rradar a JSC letter and false assessment materials
- Steyn J refused adjournment and ordered proof from Lodhia and Ms Verrell
- Lodhia sent an altered order and draft witness statement to Ms Verrell
- Linden J ordered evidence on costs, trustee letters and Chiffers’ role
- Linden J ordered indemnity assessment, a GCRO and referrals
Why this case matters
Lodhia is a rare AI-explanation case where the court rejected the asserted hallucination story after testing metadata, chronology and third-party evidence. Unlike Harber, where an unrepresented party filed fake tax cases, this record involved false evidence, an altered court order, costs documents and a barrister-supervision referral. It also extends Ayinde’s regulator-referral line: the litigant was referred to the Attorney General for possible contempt, while direct-access counsel and his company were sent to the BSB over supervision and practice controls.
Practice note
AI cannot be used as an explanation for documents that a party files without reading. A litigant or direct-access team should retain originals, metadata and prompts, compare every exhibit to the source document before service, and never send an altered order or draft witness statement to a third party. If a non-lawyer works under chambers branding, supervision and retainer terms must be written down.
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, “Lodhia v Twelve Trees, [2026] EWHC 1889 (KB)”, safelegalai.com/tracker/lodhia-v-twelve-trees (accessed 2026-10-07). Data: CC BY 4.0.