D (A Child) (Recusal)
Court of Appeal · Dec 9, 2025
What happened in this matter?
The Court of Appeal identified that a pro se litigant used AI to generate legal submissions containing fabricated case citations and misrepresented authorities. The court issued a warning regarding the duty of all parties to verify the accuracy of legal citations, noting that AI-generated content can lead to significant procedural delays and potential misinformation.
- Why the court cared
- Misrepresented: Case Law | Mother cited Re W [2010] UKSC 12 for the proposition that 'findings reached through a procedurally compromised process cannot stand', an attribution the court found to be incorrect. || Misrepresented: Case Law | Mother cited Re B [2008] UKHL 35 for a proposition it does not support (asserting it showed the father's wilful evasion); court recorded this as an incorrect attribution. || Fabricated: Case Law | Mother cited a non-existent case in her skeleton/recusal documents; father’s counsel identified the citation as fabricated and the court noted AI use.
- Why it matters now
- Pro-se family-law filers in UK appellate courts are now flagged for AI-fabricated authorities; verify every cite on opposing submissions.
Why this matter is tracked
In a family law appeal, the mother, appearing pro se, submitted skeleton arguments containing multiple AI-generated hallucinations. The Court of Appeal noted that the mother cited non-existent cases and misrepresented established authorities, such as Re B [2008] UKHL 35 and Re W [2010] UKSC 12, to support propositions they did not contain. The mother admitted to using artificial intelligence to assist in preparing her documents. The court addressed these errors while ruling on broader procedural appeals regarding judicial recusal. The court emphasized that all litigants, including those appearing in person, have a duty to ensure cited authorities are genuine and accurate, warning that reliance on AI tools without verification risks misleading the court and incurring unnecessary costs.
Pro-se family-law filers in UK appellate courts are now flagged for AI-fabricated authorities; verify every cite on opposing submissions.
Record details
What the record establishes about AI use
The judgment refers to the use of artificial intelligence without naming a specific tool.
Appellate review of three consolidated appeals concerning a district judge's recusal, a subsequent order setting aside fact-finding, and a refusal to provide reasons for recusal.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
3 citation, quotation, or authority issues are recorded in the source dataset.
- Misrepresented: Case Law | Mother cited Re W [2010] UKSC 12 for the proposition that 'findings reached through a procedurally compromised process cannot stand', an attribution the court found to be incorrect.
- Misrepresented: Case Law | Mother cited Re B [2008] UKHL 35 for a proposition it does not support (asserting it showed the father's wilful evasion); court recorded this as an incorrect attribution.
- Fabricated: Case Law | Mother cited a non-existent case in her skeleton/recusal documents; father’s counsel identified the citation as fabricated and the court noted AI use.
Questions this record answers
- What happened in D (A Child) (Recusal)?
- The Court of Appeal identified that a pro se litigant used AI to generate legal submissions containing fabricated case citations and misrepresented authorities. The court issued a warning regarding the duty of all parties to verify the accuracy of legal citations, noting that AI-generated content can lead to significant procedural delays and potential misinformation.
- Why does D (A Child) (Recusal) matter for legal AI risk?
- Pro-se family-law filers in UK appellate courts are now flagged for AI-fabricated authorities; verify every cite on opposing submissions.
- What does the public record establish about D (A Child) (Recusal)?
- 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.
- Which source supports this D (A Child) (Recusal) summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.