Incident Tracker / United Kingdom
Tobosaru v Court of Law Craiova, Romania, [2026] EWHC 1720 (Admin)
·High Court of England and Wales (King's Bench Division, Administrative Court)·UKOther
In the High Court (Administrative Court), the Crown Prosecution Service filed extradition submissions citing two non-existent authorities, Vlad v Romania and Jeziorski v Poland, that the CPS later accepted likely originated from AI. The error was caught before the hearing; the appeal was dismissed on its merits and the CPS reviewed 78 other cases.
- Court
- High Court of England and Wales (King's Bench Division, Administrative Court)
- Date
- 2026-07-08
- Who used the AI
- Not recorded
- AI tool
- Not identified in the record
- Conduct
- In extradition proceedings the Crown Prosecution Service filed grounds of opposition and submissions citing two non-existent authorities, Vlad v Romania and Jeziorski v Poland. The CPS accepted the citations were inaccurate and likely originated from the use of artificial intelligence with inadequate human verification.
- Outcome
- Other
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- Not separately recorded
What was fabricated or misused
- Vlad v Romania [2017] EWHC 2060 (Admin) — no such authority exists
- Jeziorski v Poland [2019] EWHC 3885 (Admin) — no such authority exists
What the court said
“Those authorities included cases cited as: Vlad v Romania [2017] EWHC 2060 (Admin) and Jeziorski v Poland [2019] EWHC 3885 (Admin). Neither of these authorities exists.”
“In its letter, dated 3 March 2026, the CPS accepted that the citations were inaccurate and explained that they were likely to have originated from the use of artificial intelligence.”
“The position of the CPS was therefore that, while the immediate source of the error may have been the use of generative artificial intelligence, the operative cause was human error in the failure to verify the authorities relied upon in formal submissions placed before the Court.”
“As far as the appeal was concerned the errors came to light prior to the hearing and therefore had no impact on argument or the court’s judgment.”
Timeline
- District Judge Zani ordered Ms Tobosaru's extradition.
- CPS grounds of opposition cited Vlad and Jeziorski.
- Respondent Submissions carried forward the non-existent authorities.
- Permission was granted and the appeals were joined.
- Appellants' representatives first raised the missing cases with the CPS.
- CPS accepted the citations were inaccurate and likely AI-originated.
- High Court dismissed the extradition appeals.
Why this case matters
Tobosaru shows AI-citation risk inside a public prosecuting authority, not only among private lawyers or litigants in person. Ayinde dealt with professional duties in civil litigation; Tobosaru concerned extradition, where a false authority could affect liberty and international obligations. The error was caught before the hearing and did not affect the outcome, but the judgment records the CPS review of 78 other files and its internal reminder that court officers must verify written submissions before service.
Practice note
Extradition teams should run a citation check before grounds of opposition or respondent submissions are served. The check should confirm that each case exists on The National Archives, BAILII or a recognised law-report source and that the cited paragraph supports the point. If counsel or an opponent finds an error, the court should be told promptly and the correction should identify how the error occurred.
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, “Tobosaru v Court of Law Craiova, Romania, [2026] EWHC 1720 (Admin)”, safelegalai.com/tracker/tobosaru-v-romania (accessed 2026-09-16). Data: CC BY 4.0.