R (on the application of Ayinde) v London Borough of Haringey; Al-Haroun v Qatar National Bank QPSC and QNB Capital LLC

In brief

The Divisional Court, hearing two cases together on lawyers' use of AI in documents put before a court, started no contempt proceedings and made regulatory referrals instead. In Ayinde, it held that the threshold for initiating contempt proceedings against the barrister was met [68], but decided not to initiate them [69] and referred her to her regulator [70]; the solicitor was referred to the Solicitors Regulation Authority [72]. In Al-Haroun, it held that "the threshold for the initiation of contempt proceedings is, accordingly, not met" and referred the solicitor to the Solicitors Regulation Authority [81], while declining a court referral of counsel to the Bar Standards Board because "we do not consider that the threshold for a court referral to the Bar Standards Board is met" [80]. The court recorded that its decision not to initiate contempt proceedings "is not a precedent". Practitioners who use AI to prepare documents put before a court remain responsible for supervision and accuracy. Failure to check AI-assisted work may attract regulatory referral and serious disciplinary consequences. Cited and reinforced in Hamid [2026] UKUT 81.

Key provisions

• supervisory obligation — Practitioner remains responsible for accuracy of AI-assisted documents : A practitioner who uses AI to draft or prepare a document put before a court or tribunal remains responsible for the accuracy and integrity of that document. Failure to supervise / check AI output may result in regulatory referral and serious disciplinary consequences.

When relevant

Any context where AI-assisted documentation is being put before a court, tribunal, regulator, or instructing solicitor; informs the practice's quality-review process for AI-assisted deliverables.