Lawyers using fake AI citations draw ire of UK judge, risking severe penalties

The High Court of England and Wales warned lawyers about the dangers of relying on AI tools like ChatGPT for legal research. Judge Victoria Sharp ruled that these generative AI tools could not conduct reliable legal research.

Judge Sharp claimed that AI tools could provide seemingly coherent and plausible responses but also be entirely incorrect. She clarified that while lawyers can use AI in their research, they have a professional obligation to check the accuracy of such research by reference to authoritative sources before using it in their professional work.

The judge’s remarks came amid rising concerns over instances where lawyers cited what appeared to be AI-generated falsehoods. Dame Sharp’s decision cited two recent cases where lawyers were found to have cited fake cases generated by AI in court proceedings. She said her ruling will be shared with professional bodies in the country, including the Bar Council and the Law Society.

Lawyer Hussain cites non-existent cases in $120M case

Lawyers, beware: The Dangers of Using AI to Draft Submissions Without Verification

In the Al-Haroun case, the court uncovered a staggering 45 citations that were either non-existent or contained inaccurate quotations. Shockingly, these false citations were originally generated… pic.twitter.com/CbgNy1z7X1

— Lawpoint Uganda (@Lawpointuganda) June 7, 2025

Lawyer Abid Hussain cited non-existent cases in a $120 million (£89M) lawsuit regarding an alleged breach of a financing agreement with Qatar National Bank. Hussain submitted a filing with 45 citations, out of which 18 did not exist, while many others did not contain the quotations that were attributed to them. 

The client, Hamad Al-Haroun, apologized for unintentionally misleading the court with false data from publicly available AI tools and said he was responsible rather than his lawyer, Hussain. But Sharp said it was “extraordinary” that the lawyer relied on the client for the accuracy of their legal research rather than the other way around.

Judge Sharp, the president of the King’s bench division, said there were serious implications for the administration of justice and public confidence in the justice system if AI was misused. She added that lawyers misusing AI could face public admonishment and referral to the police. She called on the Bar Council and the Law Society to consider steps to curb the problem “as a matter of urgency.”

The judge also asked heads of barristers’ chambers and managing partners of lawyers to ensure all lawyers understood their professional and ethical duties when using AI.

“The responses may make confident assertions that are simply untrue. They may cite sources that do not exist. They may purport to quote passages from a genuine source that do not appear in that source.”

–Judge Victoria Sharp, President of the King’s Bench Division

Ian Jeffery, the Chief Executive of the Law Society of England and Wales, said the ruling laid bare the dangers of using AI in legal work. He added that AI tools were increasingly used to support legal service delivery. Still, the real risk of incorrect outputs produced by generative AI requires lawyers to check, review, and ensure the accuracy of their work.

Advocate Forey cites five fake cases in a tenant’s housing claim

Barrister Sarah Forey cited five fake cases in a tenant’s housing claim against the London Borough of Haringey. Forey denied using AI, but Sharp said she had not provided the court with a coherent explanation for what happened.

The judge also warned that offering false material as genuine might be considered contempt of court or, in “the most egregious cases,” perverting the course of justice. She added that this could lead to severe penalties for lawyers who did not comply with their professional obligations.

Sharp said Forey showed a worrying lack of insight, adding that the court did not accept that a lack of access to textbooks or electronic subscription services within chambers, if that was the position, provided anything more than marginal mitigation.

She asserted that Forey could have checked the cases she cited by searching the National Archives caselaw website or by going to the law library of her Inn of Court. Sharp observed that Forey must have deliberately included fake citations or used AI despite denying it in her witness statement.

Last month, Justice Ritchie said that, in citing five fake cases, the behavior of Forey, then a pupil at 3 Bolt Court, and the lawyers at Haringey Law Centre in London was improper, unreasonable, and negligent. He also ordered all of them to pay wasted costs. 

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