Most managing partners have read a summary of Ayinde and stopped there. The summary is accurate and not much use: submissions put before a court cited authorities that did not exist. What a partner needs from the judgment is the list of things that were absent in both matters, because those absences are the ones your own firm is either carrying or has already closed. What follows is a plain reading of R (Ayinde) v London Borough of Haringey and Al-Haroun v Qatar National Bank QPSC [2025] EWHC 1383 (Admin), and four things to change before the next quarter ends.
What happened, in six lines
Two separate matters were heard together by the Divisional Court, with Dame Victoria Sharp P presiding, and judgment was given in June 2025. In each, material put before the court cited authorities that did not exist. The court made wasted costs orders and referred matters to the regulators. It also set out what it expects of lawyers who use these tools.
Read the judgment itself rather than any commentary on it, including this page. It is free to read on public sources, and a partners' meeting that has read it is a different meeting from one working off a trade headline. If you circulate one document to the partnership this quarter, circulate that one.
Why a court treats this differently from an ordinary error
An error of law in a skeleton argument is argued about. A citation to a case that does not exist is a different category of problem, because the whole system of precedent runs on the court being able to rely on what practitioners tell it. Judges do not independently re-derive the law from first principles in every hearing. They read what is cited, and the opponent reads it too, and the process assumes that both sides have looked at the thing they are quoting.
That is why the response reached costs and regulators rather than a remark in the judgment. The consequence a firm should plan for is not a costs order in a single matter. It is the position of the fee-earner, the supervisor and the firm when someone asks, afterwards, what was checked before the document went out, and by whom.
The three failures behind one bad citation
A fabricated authority reaching a court is rarely one person's mistake. It is three controls failing in sequence. First, no verification step existed between the model's output and the draft: nobody opened the case. Second, no supervision step caught it, because the citation looked exactly like every other citation on the page and the supervisor was reading for argument, not for existence. Third, nobody owned the check, which means it was everyone's job and therefore no one's.
The third failure is the one a managing partner can actually fix this month. Verification and supervision are practices that take time to bed in. Ownership is a decision taken in a meeting. Until a named person is responsible for the authorities in a document that leaves the firm, the other two controls sit with whoever happened to be least busy on the day.
Four changes worth making this quarter
One: write down which tools are sanctioned and which are not, and put the list somewhere a fee-earner will see it at four in the afternoon. Two: make the authorities in any document going to a court, a client or the other side a named responsibility, recorded on the file. Three: require the source to be opened, not searched for. A search that returned nothing is evidence. A search nobody ran is not.
Four: decide what your firm does when a check fails. If the answer is take it out and carry on, say so. If the answer is tell the supervising partner, say who. The value of a rule here is not its sophistication. It is that a tired associate at seven in the evening knows what it is without having to ask anyone.
What supervision looks like on the file
The SRA added AI-specific sections to its Effective Supervision guidance in June 2026, and its guidance update on new technology and COLP responsibility in February 2026 puts the compliance officer in the frame where technology is doing part of the work. Both point at the same practical question: what does the file show about how the output was checked.
A supervision record that answers that question is short. Which tool was used, on what question, against which sources, what came back unconfirmed, who read it, and what they did about it. Six lines. A firm that can produce those six lines for any piece of AI-assisted work has a better answer than a firm with a twelve-page policy and nothing on the file.
How LegalAI Space handles the citation half of this
Research in LegalAI Space reads only a fixed list of 74 approved public sources, including legislation.gov.uk, BAILII, the National Archives Find Case Law service, EUR-Lex and the FCA, ICO and SRA handbooks. Ten paywalled domains are refused by name, among them Westlaw, Practical Law, LexisNexis, Bloomberg Law, Justis and vLex, because a page the checker cannot open is a page it cannot confirm.
Every authority in an answer carries a verdict of verified, needs a check, or not found, and a 'Where we looked' panel shows what was searched. Verified means the cited passage was found, word for word, on an approved source. A fabricated case earns not found, and there is a 'Verify all authorities' action, so the check is something you repeat on demand rather than something you remember to do. Each run is written to the audit and compliance register with who authorised it and whether the checks passed.
A checklist for the partners' meeting
Six questions, in order. Do we know which AI tools our people use, including the ones nobody asked us about. Is there a named owner for the authorities in every document that leaves the firm. Can we show, on any given file, which sources were checked. Do our fee-earners know what to do when a check fails. Does our supervision record cover AI-assisted work specifically, rather than work in general. And could we produce all of that for a matter from three months ago, this afternoon.
If five answers are yes and one is no, you have a task rather than a problem. If four are no, the exposure is not theoretical. It is the same shape as the exposure in the two matters the Divisional Court heard together in June 2025.
What this does not do
Verification does not make fabrication impossible. A model can still write a citation into prose. What the checker decides is the verdict that citation carries, and whether the work can leave the firm while it is unconfirmed. It also cannot tell you whether an authority that genuinely exists supports the proposition it has been cited for. That reading belongs to the supervising solicitor, and no verdict replaces it.
Coverage is England and Wales, with EU, Irish and ECHR primary law in the source list. It is not US, Canadian or Australian law. There are no live connectors to iManage, NetDocuments or SharePoint; those are catalogue tiles, and documents come in by upload. And nothing here is a certification. The SRA does not approve products, so a vendor claiming otherwise is describing something the regulator has never issued.
