Ayinde v Haringey and Al-Haroun v Qatar National Bank

The timeline

• AyindeSarah Forey, counsel for the claimant in a housing judicial review against the London Borough of Haringey, cites five cases that do not exist. One neutral citation given, [2020] EWHC 2435 (Admin), belongs to an unrelated case about business rates.
• Al-HarounIn a separate commercial claim, forty-five citations are put before the court; eighteen of them do not exist. The solicitor relied on research produced by his own lay client.
• First instanceRitchie J makes a wasted costs order of £2,000 against Ms Forey in the Ayinde proceedings.
• 6 Jun 2025The Divisional Court hands down a single judgment in both matters.

What the AI did

The court’s framing is the part worth carrying into practice, because it does not depend on the tool:

“Those coherent and plausible responses may turn out to be entirely incorrect.”

The court directed that output be verified “by reference to authoritative sources”, and named them: official government databases, The National Archives and the published Law Reports. That is a materially stricter instruction than the American cases, which mostly say “read the case”. Here the court told practitioners which sources count.

What the court did, and why

• AyindeThe £2,000 wasted costs order against Ms Forey stood. She was referred to the Bar Standards Board. Mr Victor Amadigwe and the Haringey Law Centre were referred to the Solicitors Regulation Authority. A paralegal, Ms Hussain, was found blameless and no action was taken.
• Al-HarounMr Abid Hussain and Primus Solicitors were referred to the Solicitors Regulation Authority; he had already self-referred. No contempt proceedings were initiated.
• Rules citedFor barristers, Core Duties 1, 3, 5 and 7 and rules C3.1, C9.1, C9.2.b and C18. For solicitors, SRA rules 1.4, 2.4, 2.6, 2.7, 3.2 and 3.5.

On contempt, the court noted that placing false material before a court “deliberately interferes with the administration of justice” and may amount to contempt, but that this requires knowledge of the falsity or the absence of an honest belief in the accuracy of the material. That is the threshold that was not crossed here, and the reason nobody went to prison.

What it changed

Three differences from the American record. The penalty is regulatory, not financial: £2,000 is trivial next to $15,000 in Whiting, but a Bar Standards Board or SRA referral runs on its own timetable and can end a practice. The court used an existing supervisory jurisdiction, Hamid, rather than a sanctions rule, so no new rule was needed. And it drew a line between the person who used the tool and the person who supervised: a paralegal was expressly exonerated while the barrister and the supervising solicitors were not.

For an English or Welsh practitioner this is the case the court will cite. For an American one it is the answer to “is this only a US problem?”

Sources

• Judgment, [2025] EWHC 1383 (Admin), Find Case Law, The National Archives
• Same judgment on BAILII
• The £2,000 figure originates in Ritchie J’s first-instance order, recorded in the Divisional Court judgment.

Related

• The full sanctions record
• Zhang v Chen, the leading Canadian decision
• Whiting v. City of Athens, the American appellate escalation
• Every verified AI standing order

Checked 5 August 2026 against the judgment as published by The National Archives. Information, not legal advice, and not advice on English law.