Insights from Ayinde v Haringey and Al-Haroun v Qatar National Bank [2025] EWHC 1383.
Legal professionals are increasingly exploring Gen AI tools to expedite procedural drafting, summarise material, conduct legal research, and respond to legal queries. These cases underscore the growing influence of artificial intelligence on evidentiary standards, legal procedures, and accessibility within the justice system. The recent rulings in Ayinde v London Borough of Haringey [2025] EWHC 1383 (Admin) and Hamad Al-Haroun v Qatar National Bank QPSC and QNB Capital LLC (jointly heard) deliver a clear and unequivocal caution to legal practitioners: Generative AI (GenAI) must not be relied upon without rigorous verification. They may assist with research, summarizing and drafting but cannot be trusted blindly, and cannot be used as a shield from professional accountability.
In Ayinde, a barrister submitted grounds of claim riddled with fictitious case law, legal inaccuracies, and unverified assertions. Similar issues arose in Al-Haroun, where a solicitor submitted a witness statement containing similarly flawed material. These actions interfered with the proper administration of justice, and the court deemed the actions of counsel improper, unreasonable, and negligent. In both instances, the practitioners were found to have knowingly or recklessly misled the court, or attempted to do so, in breach of their professional obligations. The consequences included wasted costs orders, and public judicial criticism.
The Court’s stance was unequivocal: Generative AI does not absolve lawyers of their professional duties. Legal practitioners remain fully accountable for the accuracy and integrity of all submissions made under their name.”
Looking Ahead
The Divisional Court’s decisions in Ayinde and Al-Haroun went beyond the conduct of the individuals involved. In both cases, the judges underscored the need for broader institutional reform. The message was clear:
- Regulatory bodies must move beyond issuing guidance alone. Formal training, effective supervision, and robust disciplinary processes must keep pace with the realities of GenAI use in legal practice.
- Junior lawyers must be held to the same professional standards as their senior colleagues; limited resources or lack of access to legal databases cannot be used as an excuse.
- Law firms must invest in clear internal policies and reliable verification processes to manage AI use, especially as GenAI becomes an integral part of legal workflows.