What was hallucinated

Fabricated: Case Law | Tribunal found 'Jordi v London Business School [2022]' to be entirely fictitious; Respondent highlighted it in its citation table and relied on that to show fabricated AI output. || Misrepresented: Case Law | Tribunal found multiple real cases were mischaracterised (misstating holdings or drawing unjustified principles) and Respondent's citation table identified 37 such misrepresentations. || Misrepresented: Case Law | Drysdale was relied on but the Tribunal found the Claimant mis-stated its holdings as relating to citation practice; Respondent pointed this out in the citation table and Tribunal agreed. || Misrepresented: Case Law | Rathakrishnan was cited as authority for extending time based on attempts to resolve matters; Tribunal found this to be a misstatement of the case. || Fabricated: Case Law | Judge recorded that 9 of the 46 citations were wholly fictitious AI-generated cases; Respondent's table documented these fabricated authorities. || Fabricated: Case Law | Tribunal identified citation 'Remploy Ltd v Abbott [2014] ICR 1114' as non-existent and therefore a fabricated citation (real related case: Remploy Ltd v Abbott [2015] 4 WLUK 492). || Misrepresented: Case Law | Hale v Brighton & Sussex University Hospitals NHS Trust was relied on via an online summary but Tribunal found the Claimant's use materially inaccurate and not supportive of his proposition.

Details

The Claimant used AI to generate case citations in his pleadings; Tribunal found 46 inaccurate or misleading citations (9 wholly fictitious, 37 misrepresentations of real cases) and concluded the conduct was reckless and unreasonable, justifying a costs order.

Sanction teardown · Employment Tribunals, UK · 2025-10-13

Hassan v ABC International Bank

What happened

In Employment Tribunals, 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:

Fabricated (Case Law)

Tribunal found 'Jordi v London Business School [2022]' to be entirely fictitious; Respondent highlighted it in its citation table and relied on that to show fabricated AI output.
Misrepresented (Case Law)

Tribunal found multiple real cases were mischaracterised (misstating holdings or drawing unjustified principles) and Respondent's citation table identified 37 such misrepresentations.
Misrepresented (Case Law)

Drysdale was relied on but the Tribunal found the Claimant mis-stated its holdings as relating to citation practice; Respondent pointed this out in the citation table and Tribunal agreed.
Misrepresented (Case Law)

Rathakrishnan was cited as authority for extending time based on attempts to resolve matters; Tribunal found this to be a misstatement of the case.
Fabricated (Case Law)

Judge recorded that 9 of the 46 citations were wholly fictitious AI-generated cases; Respondent's table documented these fabricated authorities.
Fabricated (Case Law)

Tribunal identified citation 'Remploy Ltd v Abbott [2014] ICR 1114' as non-existent and therefore a fabricated citation (real related case: Remploy Ltd v Abbott [2015] 4 WLUK 492).
Misrepresented (Case Law)

Hale v Brighton & Sussex University Hospitals NHS Trust was relied on via an online summary but Tribunal found the Claimant's use materially inaccurate and not supportive of his proposition.

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

Costs Order (monetary penalty: 5881 GBP.)

Additional detail

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.

Check a brief before you file it → · See our live false-verify rate

Source: https://naturalandartificiallaw.com/thirty-uk-hallucinated-citations/#S_Peggie_v_Fife_Health_Board_and_Dr_B_Upton, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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