D (A Child) (Recusal)
Court of Appeal · Dec 9, 2025
- Jurisdiction
- international
- Court
- Court of Appeal
- Record ID
- d-a-child-recusal-2025-12-09
- Observed outcome
- The court issued a warning regarding the duty to verify AI-generated legal citations and set aside the district judge's recusal decision, remitting the underlying appeal for rehearing.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
Pro-se family-law filers in UK appellate courts are now flagged for AI-fabricated authorities; verify every cite on opposing submissions.
Failure modes and consequences
- Fabricated_case_law
- Misrepresented_legal_authority
- Pro Se
- Fake Citations
- Misrepresented Authority
- Family
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- Not recorded
- Procedural posture
- 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.
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
The judgment refers to the use of artificial intelligence without naming a specific tool.
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.