The legal world is increasingly engaging with artificial intelligence (AI), but a recent case has highlighted the risks of relying on AI for legal research. In two notable incidents, a solicitor and a barrister used generative AI tools to cite case law—only to discover the citations were fabricated.
In The Ayinde and The Al-Haroun case [2025] EWHC 1383 (Admin), senior Judges warned:
‘Freely available generative artificial intelligence tools, trained on a large language model such as ChatGPT are not capable of conducting reliable legal research. Such tools can produce apparently coherent and plausible responses to prompts, but those coherent and plausible responses may turn out to be entirely incorrect. 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.’
This statement underlines a serious concern. Generative AI tools are trained to produce fluent, plausible-sounding responses—not necessarily accurate legal information. Their confident tone can be misleading, often quoting or referencing legal material that is either misrepresented or completely fictional.
It’s also important to note that litigants in person share also must not mislead the court. This responsibility includes verifying every legal citation used in their submissions or court documents.
Best Practice for Using AI in Legal Research
- Always cross-check AI-generated citations with official case law databases.
- Use AI as a starting point, not a source of authority.
AI can enhance efficiency, but when it comes to legal case citations, human oversight is essential. The bottom line? Be cautious, be thorough, and always verify.