Ravinder Dhillon, a senior crown prosecutor representing the Crown Prosecution Service (CPS), presented a fictitious legal case, "CPS – R v J EWCA Crim 3529," during a High Court dispute in October. The case concerned whether an 11-year-old boy should face prosecution for the alleged rape of his seven-year-old sister. Dhillon's submission, which included a detailed reference to the nonexistent case, was later attributed to an AI-generated summary from an internet search.
Lawyers for the boy challenged the CPS's decision to prosecute, arguing that prosecutors had not considered representations from social workers, youth workers, and a forensic psychologist. Dhillon had initially decided to proceed with the prosecution in April, a decision confirmed by the chief crown prosecutor. In October, Dhillon admitted the citation error, stating she had intended to refer to a genuine, different decision made 15 years prior.
Two senior High Court judges deemed Dhillon's explanation "unsatisfactory," and Brian Flanagan, an associate professor of law at Maynooth University, called the incident a "serious failure." Flanagan emphasized that legal authorities are "precious things" that cannot be fabricated, and AI increases the risk of such occurrences due to the time savings it offers.
The High Court acknowledged the error but stated it did not affect the outcome of the boy's challenge to the prosecution decision. The boy's trial is scheduled to proceed in youth courts later this week.
This marks the second known instance where the CPS has cited nonexistent legal authorities, reportedly due to AI. In February, the CPS acknowledged a similar error by one of its lawyers in an extradition case, which involved two Romanians convicted of minor offenses. Those fabricated cases were only identified when opposing lawyers could not find any trace of them. At that time, the CPS concluded that the "risk of recurrence was low."
The CPS maintains a strict AI policy that limits its use to avoid making legal decisions and mandates human checks for accuracy. A spokesperson for the CPS stated that the service "identified an error had occurred from conducting legal research using the internet." They added that the error was remedied, an internal review was conducted to determine its cause and check for other affected cases, and learnings were shared, including the directive that case law must be cited from trusted legal sources.
The High Court, in June 2025, responded to previous AI hallucinations in various cases, from housing to banking, by urging the Bar Council and the Law Society to address the issue "as a matter of urgency." Dame Victoria Sharp, then president of the King's Bench Division, warned of "serious implications for the administration of justice and public confidence in the justice system if artificial intelligence is misused." She also indicated that lawyers misusing AI could face sanctions, including public admonishment, contempt of court proceedings, and referral to the police.