High Court refers a solicitor to his regulator after fictitious citations from research his client says was AI-generated were put before the court

The filings. The claimant sought damages of about £89.4 million for alleged breaches of a financing agreement against Qatar National Bank and QNB Capital. After Dias J extended the defendants' time to file evidence in April 2025, the claimant applied to set that order aside, relying on his own witness statement and one from his solicitor. On 9 May 2025 Dias J dismissed the application and referred the papers to the Hamid judge, recording that correspondence with the court and both witness statements relied on numerous authorities which appeared to be either completely fictitious or, if they existed, did not contain the passages quoted or did not support the propositions cited. The judicial assistant's schedule listed 45 citations; in 18 instances the case cited did not exist, and many of the real cases were misquoted or irrelevant.

The AI research. In his witness statement the claimant accepted responsibility for the inaccurate and fictitious material and said the citations had been generated using publicly available artificial intelligence tools, legal search engines and online sources. He said he had complete, though misplaced, confidence in the authenticity of the material and did not intend to mislead; he sought to absolve his solicitor. No tool is named, and no query, output or date of the research is recorded.

The solicitor. The solicitor's statement accepted that his own witness statement cited non-existent authorities and said he had relied on the client's legal research without independently verifying it. He said he had never previously been reported to the Solicitors Regulation Authority, had reported himself, had removed himself from all litigated matters and would undertake training. His counsel accepted that the conduct could not be worse and that the last thing a solicitor should do is rely on a lay client's research, pointing in mitigation to the self-referral and to the fact that a barrister who had seen the documents had not flagged the fake citations.

The court's conclusions. The Divisional Court (the President of the King's Bench Division and Johnson J) accepted that the claimant had no intention to mislead but said its focus was on the lawyers: it was extraordinary that the lawyer was relying on the client for the accuracy of legal research rather than the other way round. It found a lamentable failure by the solicitor and his firm to check the accuracy of material put before the court, was satisfied that he did not realise the true position, held that the threshold for contempt proceedings was not met, noted his self-referral and said it would also make a referral to the Solicitors Regulation Authority. It did not refer the barrister to the Bar Standards Board. In its wider remarks the court said these Hamid cases showed that regulatory guidance on its own was insufficient to address the misuse of artificial intelligence, and sent the judgment to the Bar Council, the Law Society and the Council of the Inns of Court.

Limits. The judgment is the only inspected source. The consequences recorded are the solicitor's own withdrawal from litigated matters and the court's referral; whether the regulator later imposed any sanction is not established. The claimant's application was dismissed on 9 May 2025, but the judgment does not attribute that dismissal to the fake citations.

The solicitor’s own statement records his withdrawal from all litigated matters and his self-referral to the Solicitors Regulation Authority, and the court said it would also refer him. No disciplinary penalty is recorded.

A litigant's legal research, which he says was generated with publicly available AI tools, legal search engines and online sources, produced citations of cases that do not exist and quotations that real cases do not contain. His solicitor adopted that research in correspondence and a witness statement without checking it. The court's response to the solicitor's failure to verify (a referral to the Solicitors Regulation Authority) and the solicitor's own withdrawal from litigated matters are the recorded professional consequences.

The solicitor reported himself to the Solicitors Regulation Authority before the hearing of 23 May 2025, and the court said in its judgment of 6 June 2025 that it would also make a referral. The court declined to initiate contempt proceedings. The judgment does not record any regulatory outcome, and none was researched for this review.