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UK High Court Flags AI-Generated Fake Legal Citation By Pinsent Masons; Refers Matter To Regulator

UK High Court Flags AI-Generated Fake Legal Citation By Pinsent Masons; Refers Matter To Regulator

Anthony Malcolm Cork v. Mark Smith, Decided on 22.05.2026

AI fake legal citation

The High Court of Justice in England and Wales has sharply criticised law firm Pinsent Masons over misleading submissions containing an artificial intelligence-generated fake legal citation in insolvency proceedings, warning of the serious risks posed by unverified AI use in legal practice.

The issue arose in a block transfer application concerning the replacement of an insolvency office-holder. ICC Judge Mullen noted that such applications are ordinarily administrative and routinely decided without a hearing, but concerns were triggered after Pinsent Masons submitted two letters to the court asserting that Rule 12.37(5) of the Insolvency (England and Wales) Rules, 2016 expressly empowered the court to grant release to an outgoing office-holder. Upon verification, the court found that the quoted provision did not exist.

The judgment records that the erroneous text had been generated through AI by a junior associate, who repeatedly relied on AI outputs despite multiple warnings from the tool itself to verify the cited legal provision from authoritative sources before using it in court filings. The court found this omission “inexcusable,” noting that the AI had expressly cautioned that the statutory wording should be independently checked.

Judge Mullen also found the law firm’s subsequent attempt to explain away the error through a follow-up letter particularly troubling, observing that the explanation lacked credibility and heightened concerns about whether the court had been misled. However, the court accepted that the applicants themselves were blameless, noting that the problematic conduct was attributable to the firm’s handling of the matter.

During the proceedings, Pinsent Masons acknowledged AI had indeed been used in preparing the impugned letters, apologised to the court, and informed that it had self-reported the matter to the Solicitors Regulation Authority (SRA). The firm also stated that it had initiated internal remedial measures and enhanced safeguards governing AI use.

The court emphasised that while AI can be a useful legal tool, lawyers remain professionally bound to verify all AI-generated research against authoritative legal sources before placing it before courts, reiterating that misuse of AI can seriously undermine the administration of justice.

Appearances

For Applicants: Mr Andrew Brown (instructed by Irwin Mitchell LLP)

For Pinsent Masons LLP: Mr Paul Mitchell KC (instructed by Clyde & Co LLP)

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Anthony Malcolm Cork v. Mark Smith

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