Judge said inaccurate legal authorities filed in appeal documents appeared to be generated using AI without proper verification
Two solicitors and their firm have been referred to the Solicitors Regulation Authority (SRA) after a court found that inaccurate legal authorities, apparently generated using artificial intelligence, were included in appeal documents filed before the court.
In Rodney v Gee’z Micro Bar & Pitstop, Judge Grimshaw criticised the conduct of solicitor Mahmood Hussain and AML Legal director Kossar Qureshi after incorrect authorities and misleading citations appeared in documents prepared for an appeal.
The court identified several inaccurate citations in the appeal bundle, including authorities that did not match the legal propositions for which they were relied upon and a neutral citation linked to an unrelated immigration case. Judge Grimshaw said the errors appeared consistent with material generated using AI tools without proper verification.
One document filed with the court included wording which the judge said strongly suggested the use of generative AI. Referring to a passage that read “Relevance: your client was a litigant in person”, the judge said it appeared to be material “churned out by AI”.
Judge Grimshaw described the conduct as “inexcusable on the part of a professionally qualified lawyer”, particularly because one of the documents had been verified with a statement of truth signed by Hussain.
The court heard that concerns about the authorities emerged after counsel for the respondent challenged the citations before a hearing in March 2026. AML Legal later instructed counsel to prepare a replacement skeleton argument acknowledging that the original version contained inaccurate case citations.
In witness evidence, Hussain accepted responsibility for the documents and admitted he had failed to verify legal research carried out by a paralegal assisting him. He also acknowledged that AI tools may have been used during preparation of the material.
Despite the criticism, Judge Grimshaw declined to initiate contempt proceedings. Referring to the Divisional Court’s ruling in Ayinde v London Borough of Haringey, the judge said there was insufficient evidence to establish that the solicitors knowingly placed false material before the court, rather than acting negligently or recklessly.
However, the court concluded that the seriousness of the conduct required regulatory scrutiny. Judge Grimshaw directed that the judgment, witness statements and related orders be sent to the SRA for consideration of possible disciplinary action against both solicitors and AML Legal.
The judgment was also ordered to be published on the Judiciary website because of the wider public importance of the issues raised concerning the use of artificial intelligence in legal practice.