Choksi v IPS
High Court · Nov 4, 2025
- Jurisdiction
- international
- Court
- High Court
- Record ID
- choksi-v-ips-2025-11-04
- Observed outcome
- The court required the defendant's managing partner and the responsible paralegal to file witness statements explaining the inclusion of AI-generated, fabricated legal authorities.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court identified that the defendant's witness statement included fabricated and irrelevant case law. A paralegal admitted to relying on Google AI Overview without verification. The court required the firm to explain the inclusion of this material, leading to an apology and claims of new internal verification protocols.
Fabricated: Case Law | Farnell 2 cited numerous authorities with wrong citations or names and included some cases that do not exist; court found several citations irrelevant and unsupported by the authorities cited. || Misrepresented: Case Law | Paralegal responsible for drafting Farnell 2 admitted part of the research used Google's AI 'Overview' feature and that AI-generated results were relied on without appreciation of limitations; court noted misuse of AI and required explanations. || Fabricated: Case Law | Claimant's solicitors identified 12 problematic citations; the bundle filed by IPS listed 6 items as 'No. Case Name (as cited)', indicating non-existent or fabricated citations.
Paralegal AI research must be supervised and logged; Google AI Overview is not on any approved-tools list and never should be.
Failure modes and consequences
- Fake Citations
- Misrepresented Authority
- Contract
- Trial
- None Adjudicated
- AI attribution
- Admitted
- Recorded tool
- Google AI Overview
- Known monetary consequence
- Not recorded
- Procedural posture
- Summary judgment application in the High Court of Justice, Chancery Division, where the court addressed deficient evidence and AI-generated hallucinations in a witness statement.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
Paralegal admitted using Google AI Overview.
Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Assign a responsible reviewer for AI-assisted research and drafting.
- Use only approved research and drafting tools for legal work.
- Train lawyers and staff to identify and verify generated legal content.