The citation looks right. Fairhurst v Meridian Holdings [2019] EWHC 2210 (Ch) — plausible parties, plausible court, plausible year, and the AI's summary says it supports exactly the point you're arguing. You could paste it into the skeleton and move on. Most of the time you'd get away with it. The one time you don't, it's a wasted-costs order and a letter to the SRA.
Verifying AI-generated citations isn't hard. It's just a step people skip under deadline pressure, or do badly by confirming the case is real without confirming it says what the AI claimed. This is the method — the sources to check, the failure most people miss, and how to make the check leave a record.
Why "it looks right" is exactly the trap
AI generates citations that are statistically plausible, which is not the same as real. It has seen thousands of citations and knows the shape: party names, a neutral citation format, a court abbreviation, a year. It can assemble that shape flawlessly around a case that was never decided.
That's why eyeballing fails. A fabricated citation is designed, by the way the model works, to survive a glance. The court in Ayinde v Haringey and Al-Haroun v Qatar National Bank (Divisional Court, 6 June 2025) put the duty plainly: lawyers must check AI research "by reference to authoritative sources." Not "if it looks off." Every time.
The four-step verification method
Work through all four for every AI-supplied authority. Steps 3 and 4 are the ones that separate real verification from theatre.
Step 1 — Confirm the case exists
Look it up in an authoritative database, not a search engine and not the AI itself. For UK case law:
- The National Archives' Find Case Law — the official record of court judgments.
- BAILII — free and widely used for UK and Irish case law.
- A reputable publisher's database — Westlaw, LexisNexis, or similar, if the firm subscribes.
If the case doesn't appear in any of these, treat it as fabricated until proven otherwise. A real case that's simply old or unreported is rare; a confidently-cited case that exists nowhere is the signature of a hallucination.
Step 2 — Confirm the citation is correct
A real case can be paired with a wrong neutral citation, year, or court — sometimes because the AI blended two cases. Check the citation on the record matches. For legislation, use legislation.gov.uk and confirm the provision is current — not repealed, not amended out from under your point.
Step 3 — Read the passage, not the summary
This is the failure almost everyone misses. The AI cites a real case, with the correct citation, for a proposition it does not actually support — or supports in dicta, or in a dissent, or in a since-overruled passage. A surface check ticks "real case, real citation" and moves on. Only opening the judgment and reading the relevant passage catches the misattribution.
Working advice: The dangerous hallucination in 2026 isn't the invented case — that's easy to catch. It's the real case cited for something it doesn't hold. If you only change one habit, make it this: read the paragraph, not the AI's description of the paragraph.
Step 4 — Record what you checked
Verification that leaves no trace is invisible to everyone who later matters. For each authority, note: what tool produced it, which source you verified against, whether it checked out, and who did the check. Under SRA Code of Conduct for Firms paragraph 2.2, your firm needs records that demonstrate compliance — and "we always verify" is a claim, while a dated verification note is evidence.
A quick reference, by document type
| What the AI gave you | Verify against | Watch for |
|---|---|---|
| A UK case | National Archives / BAILII / reputable publisher | Non-existent case; wrong citation; wrong holding |
| A statute or section | legislation.gov.uk | Repealed or amended; not yet in force |
| An EU instrument | EUR-Lex | Superseded version; wrong article |
| A direct quotation | The judgment itself | Fabricated or altered wording |
When to stop doing this by hand
The method is simple, but doing it manually for every citation, on every matter, under deadline, is where it breaks — not because lawyers are careless, but because it's repetitive work that competes with billable time. That's the argument for verification built into the tool rather than bolted on by a tired human at the end.
The property that matters: does the system re-fetch each cited authority from the authoritative source independently of the model that generated it, confirm existence and support, and record the result? A model reviewing its own citations is asking the fabricator to mark its own homework. An independent re-fetch against the National Archives, legislation.gov.uk and EUR-Lex is a genuine fact check — and it produces the step-4 record automatically.
- If you're a fee-earner: until your tools verify for you, do all four steps by hand, and never let step 3 slide. The real-case-wrong-holding error is the one that looks most credible in a filing.
- If you're choosing tools: treat "verifies citations against primary sources, with a record" as a requirement, not a nice-to-have. It's the difference between a tool that creates risk and one that removes it.
- If you're the COLP: this is the control that most directly answers "what the SRA can ask about AI" — can you show, for a given matter, that cited authorities were verified?
FAQ
How do I check if an AI-generated case citation is real? Look it up in an authoritative database — the National Archives' Find Case Law, BAILII, or a reputable publisher — not in a search engine and not by asking the AI again. If it appears nowhere authoritative, treat it as fabricated.
Isn't it enough to confirm the case exists? No. The subtler and more common 2026 failure is a real case cited for a proposition it doesn't support. You have to read the actual passage, not the AI's summary of it.
Where do I verify UK legislation an AI cited? legislation.gov.uk, checking the provision is current — not repealed, superseded, or not yet in force.
Do I need to record that I verified citations? Yes, in practice. SRA Code of Conduct for Firms paragraph 2.2 requires records demonstrating compliance, so a dated note of what was checked and by whom is what protects you if it's ever questioned.
Can software verify AI citations automatically? Yes — the reliable approach re-fetches each authority from the primary source independently of the model that generated it, confirms it supports the point, and records the check, rather than asking the AI to review its own work.
LegalAI Space verifies every citation by re-fetching it from BAILII, legislation.gov.uk and EUR-Lex — independently of the model — and records the result as part of a signed audit trail. Book a 30-minute call with Daman to see it run.
Related reading
- AI for legal research: how to use it without getting burned — the wider workflow this verification step sits inside.
- 1,600+ AI hallucination cases — what unverified citations do in real courts.
- What the SRA can actually ask about AI — why the verification record matters to the regulator.