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Elden v HMRC

Court
First-tier Tribunal
Jurisdiction
UK
Decided
2026-01-08
AI tool
Unidentified
Outcome
Order to include statements of truth about AI use
Monetary penalty
None reported

What was hallucinated

Misrepresented: Case Law | Skeleton summarized Atlantic Electronics Ltd v HMRC [2012] UKUT 45 (TCC) as if it were a strike-out authority; Tribunal read the full 9-page decision and found the summary inaccurate and irrelevant (case concerned MTIC VAT and admission of additional evidence). || Misrepresented: Case Law | Skeleton presented Leeds City Council as if it were about denying a full hearing/strike-out; Tribunal read the 11-page decision and found the skeleton's summary misleading (case concerned costs and delay, not strike-out). || Misrepresented: Case Law | Skeleton misdated and mischaracterised Hok Ltd v HMRC (cited as 2011) and presented it as a strike-out authority; Tribunal found this inaccurate (case concerns PAYE penalties, not strike-out) and noted the misattribution. || Misrepresented: Case Law | Passages in the skeleton attributed to 'Hok' were in fact taken from Biguzzi v Rank Leisure plc [1999] 1 WLR 1926 (CA); Tribunal concluded case-heading/citation substitutions had occurred, producing materially misleading summaries.

Sanction teardown · First-tier Tribunal, UK · 2026-01-08

Elden v HMRC

What happened

In First-tier Tribunal, UK, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

  • Misrepresented (Case Law)
    Skeleton summarized Atlantic Electronics Ltd v HMRC [2012] UKUT 45 (TCC) as if it were a strike-out authority; Tribunal read the full 9-page decision and found the summary inaccurate and irrelevant (case concerned MTIC VAT and admission of additional evidence).
  • Misrepresented (Case Law)
    Skeleton presented Leeds City Council as if it were about denying a full hearing/strike-out; Tribunal read the 11-page decision and found the skeleton's summary misleading (case concerned costs and delay, not strike-out).
  • Misrepresented (Case Law)
    Skeleton misdated and mischaracterised Hok Ltd v HMRC (cited as 2011) and presented it as a strike-out authority; Tribunal found this inaccurate (case concerns PAYE penalties, not strike-out) and noted the misattribution.
  • Misrepresented (Case Law)
    Passages in the skeleton attributed to 'Hok' were in fact taken from Biguzzi v Rank Leisure plc [1999] 1 WLR 1926 (CA); Tribunal concluded case-heading/citation substitutions had occurred, producing materially misleading summaries.

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Order to include statements of truth about AI use

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

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Source: https://www.damiencharlotin.com/documents/1283/Gary_Elden_v_The_Commissioners_for_HMRC_UK_8_January_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1283/Gary_Elden_v_The_Commissioners_for_HMRC_UK_8_January_2026.pdf

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