Ayinde v Haringey / Al-Haroun v Qatar National Bank: the UK High Court's landmark ruling on AI-fabricated case-law

The problem

Generative AI tools can produce fluent legal prose that cites cases which do not exist, and when lawyers put that output before a court without checking it, false authorities enter the record, as the source set out. The England & Wales Divisional Court (Dame Victoria Sharp P and Johnson J) took up two such cases together under its Hamid jurisdiction — the court’s inherent power to enforce the duties lawyers owe to the court ([2025] EWHC 1383 (Admin), source). The court’s reasons framed the referrals as arising “out of the actual or suspected use by lawyers of generative artificial intelligence tools to produce written legal arguments or witness statements which are not then checked, so that false information (typically a fake citation or quotation) is put before the court” (source).

What was built

The scale of the fabrication: five non-existent authorities in Ayinde, and 18 of 45 citations fictitious in Al-Haroun. There is no deployment to celebrate here — this is an AI-governance honest-negative. In Ayinde, a judicial review over interim homelessness accommodation brought against the London Borough of Haringey, pupil barrister Sarah Forey (instructed by Haringey Law Centre) cited five case authorities that do not exist, and a High Court judge referred the matter to professional regulators, as reported by the source. In the companion Al-Haroun case — a damages claim against Qatar National Bank — source records that “the schedule of references referred to by Dias J lists forty five citations that had been put before the court. In eighteen instances, the case cited does not exist”. There, the litigant said “the citations were generated using publicly available artificial intelligence tools, legal search engines and online sources” (source), an admission source independently reported (“the claimants made 45 case-law citations, 18 of which turned out to be fictitious … The claimant admitted using publicly available AI tools”).

The outcome

The order: £2,000 in wasted costs against each of Ms Forey and Haringey Law Centre, referred to the Bar Standards Board and the Solicitors Regulation Authority. On the earlier wasted-costs application, Ritchie J found the conduct improper, unreasonable and negligent, and “ordered Ms Forey and the Haringey Law Centre each to pay £2,000 to the defendant [and] also required the matter to be referred to the Bar Standards Board and the Solicitors Regulation Authority” (source). That exact £2,000-each order was reported firsthand by three separate legal newsrooms — source (“He ordered Ms Forey and Haringey Law Centre to each pay £2,000”), source (“He ordered both Forey and the solicitors to personally pay £2,000 each”), and source (“he ordered Forey and Haringey Law Centre to each pay £2,000”). On 6 June 2025 the Divisional Court held, in the Ayinde case, that “the threshold for initiating contempt proceedings is met” (source), but added: “we have decided not to initiate contempt proceedings or to refer the case to the Law Officers” (source). source reported that, the barrister having been “referred to the BSB by Ritchie J and [having] also self-referred, the court would also do so”, and the source stressed that the court’s decision “not to initiate contempt proceedings in respect of Ms Forey is not a precedent”.

On the AI attribution — the honest limit, named where you meet the claim: the court did not find that Ms Forey used ChatGPT or any named product; the AI question in Ayinde is genuinely unresolved and rests on secondary reporting, not an admission. It set out two possibilities — deliberate fabrication, or that “she did use generative artificial intelligence tools to produce her list of cases and/or to draft parts of the grounds of claim … [in which event] her denial (in a witness statement supported by a statement of truth) is untruthful” — and held both would meet the contempt threshold without adjudicating which occurred (source). source — the single independent secondary carrying this point, and therefore the weakest load-bearing link on the AI-denial detail — reported that “the barrister denied using AI in that case but said she may have inadvertently done so while using Google or Safari”. Only in Al-Haroun did a party admit AI use.

Verification status: PENDING — publish-ready, awaiting human confirmation of the referral outcome and no-appeal currency; not verified.

Path to green

The court-stated facts need no client confirmation: the origin is a published, citable High Court judgment ([2025] EWHC 1383 (Admin)), byte-tied to a contemporaneous organic Wayback capture. The exact “£2,000 each” wasted-costs figure is now bound firsthand to three independent legal newsrooms — Legal Futures, Legal Cheek and RollOnFriday — each byte-tied to its own organic Wayback capture, so both critical claims stand at two_independent. The remaining human step is confirming the outcome of the BSB/SRA referrals and that no appeal disturbed the orders — a post-judgment currency check, not a gate on the court-ordered facts. No green badge is sought: this is a court-origin honest-negative and verified is human-only.

How this was verified

• Method: Every quoted figure and finding was read verbatim from sources fetched this session and re-bound against local captures with tools/quotecheck.py (17 quotes, 0 misses). No number is paraphrased, rounded, or recalled.
• Primary anchor: The independent-origin High Court judgment, [2025] EWHC 1383 (Admin), retrieved from judiciary.uk and byte-tied to organic Wayback capture 20250606190237 (judgment day, 6 June 2025).
• Standard: Court-origin. The outcome is the adjudicated sanction and referral, so the public record — not any subject’s confirmation — is the proof; green never depends on the sanctioned lawyers or the court agreeing.
• Independence: The exact “£2,000 each” figure is carried firsthand by three mutually independent legal newsrooms (Legal Futures, Legal Cheek, RollOnFriday), each byte-tied to its own organic Wayback capture; the contempt outcome is independently reported by the Law Gazette, Legal Futures and The Guardian.
• Open item: Confirming the outcome of the BSB/SRA referrals and that no appeal has disturbed the orders — a post-judgment currency check, not a gate on the court-ordered facts.
• Verified on: 2026-07-27 (presentation rebuilt 2026-08-19; figures re-verified live 2026-08-20: the £2,000-each order and “five fake cases” against RollOnFriday, and the 45-citations/18-fictitious count against Legal Futures).

Related case files

• Arabyads v Alam (ADGM Court of First Instance) — AED 282,508 indemnity costs after AI-fabricated authorities in an English-law commercial court — the closest common-law sibling: a court applying English-law procedure sanctioning the same conduct, but through a costs order rather than the contempt/regulator route.
• McCarthy v DEA (3d Cir.) — public reprimand of an attorney for AI-fabricated authorities, first impression — a US appellate court reaching a non-monetary discipline where Ayinde declined contempt but still referred the lawyers on.
• Amar Singh v Frontier Airlines (10th Cir.) — $1,000 sanction and Maryland-bar referral for seven ChatGPT-fabricated citations — the same fabrication-plus-referral pattern with a named product admitted, the admission Ayinde never obtained.
• Fletcher v Experian (5th Cir.) — $2,500 sanction under FRAP 46(c) for AI-fabricated citations — a comparably sized monetary sanction, useful for reading the £2,000-each order against a US appellate benchmark.

Sources

1. [Tier 1] High Court of Justice, King’s Bench Division (Divisional Court) — R (Ayinde) v London Borough of Haringey; Al-Haroun v Qatar National Bank QPSC & Anor, [2025] EWHC 1383 (Admin) · judgment · 6 June 2025 · https://www.judiciary.uk/wp-content/uploads/2025/06/Ayinde-v-London-Borough-of-Haringey-and-Al-Haroun-v-Qatar-National-Bank.pdf
2. [Tier 2] Law Gazette · “‘Professional shame’: High Court judge flags lawyers to SRA and BSB over five fake case citations” · 7 May 2025 · https://www.lawgazette.co.uk/news/appalling-high-court-judge-alerts-regulators-over-fake-case-authorities/5123200.article
3. [Tier 2] Law Gazette · “Lawyers escape contempt proceedings over fake citation cases — but set to face regulators” · 6 June 2025 · https://www.lawgazette.co.uk/news/lawyers-escape-contempt-proceedings-over-fake-case-citations/5123511.article
4. [Tier 2] Legal Futures · “Court issues stark warning to lawyers over AI-generated fake cases” · 6 June 2025 · https://www.legalfutures.co.uk/latest-news/court-issues-stark-warning-to-lawyers-over-ai-generated-fake-cases
5. [Tier 2] Legal Futures · “Judge condemns lawyers who produced ‘fake citations’ to court” · 7 May 2025 · https://www.legalfutures.co.uk/latest-news/judge-condemns-lawyers-who-produced-fake-citations-to-court
6. [Tier 2] Legal Cheek · “Judge fury after ‘fake’ cases cited by rookie barrister in High Court” · 8 May 2025 · https://www.legalcheek.com/2025/05/judge-fury-after-fake-cases-cited-by-rookie-barrister-in-high-court/
7. [Tier 2] RollOnFriday · “Judge slams ‘appalling’ misbehaviour of barrister who invented five cases” · 9 May 2025 · https://www.rollonfriday.com/news-content/judge-slams-appalling-misbehaviour-barrister-who-invented-five-cases
8. [Tier 2] The Guardian · “High court tells UK lawyers to stop misuse of AI after fake case-law citations” · 6 June 2025 · https://www.theguardian.com/technology/2025/jun/06/high-court-tells-uk-lawyers-to-urgently-stop-misuse-of-ai-in-legal-work