Introducing the AI Deepfake Database, 47 UK Hallucination Cases (Suspected or Confirmed) and Lessons from the Employment Tribunal
I continue to hold the view that, serious though hallucinations are, they do not come close to the evidential challenges posed by deepfake material. Deepfake evidence may prove to be one of the most significant issues we will need to confront as a profession and I remain concerned about how any jurisdiction will respond once the problem becomes more acute.
Table of Contents
This legal article/report forms part of my ongoing legal commentary on the use of artificial intelligence within the justice system. It supports my work in teaching, lecturing, and writing about AI and the law and is published to promote my practice. Not legal advice. Not Direct/Public Access. All instructions via clerks at Doughty Street Chambers. This legal article concerns the International AI Deepfake Database Tracker and AI hallucination cases (AI suspected or confirmed). Subscribe to the AI Law Commentary here.
Publication date: 22 February 2026
Quotes
“It will be possible with AI to create– you know, a video, easily. Where it could be Scott saying something, or me saying something, and we never said that,…And it could look accurate. But you know, on a societal scale, you know, it can cause a lot of harm.”
Sundar Pichai, CEO of Google (remarks in a 60 Minutes interview, reported by Fox Business
“Society has to deal with this problem more generally, but people are going to have to change the way they interact. They are going to have to change the way they verify, like this person calling me. Right now it is a voice call. Soon it is going to be a video FaceTime. It will be indistinguishable from reality. Teaching people how to authenticate in a world like that, how to think about the fraud; this is a huge deal.”
Sam Altman (CEO, OpenAI), fireside chat with Vice Chair for Supervision Michelle W. Bowman, Integrated Review of the Capital Framework for Large Banks Conference (Federal Reserve), 22 July 2025 (official transcript, pp 9–10)
Introduction
I have attended several recent presentations where AI hallucinations continue to dominate discussion in AI law circles. They remain the issue I am most frequently asked to speak on and advise about. However, I continue to hold the view that, serious though hallucinations are, they do not come close to the evidential challenges posed by deepfake material. Deepfake evidence may prove to be one of the most significant issues we will need to confront as a profession and I remain concerned about how any jurisdiction will respond once the problem becomes more acute.
So what are deepfakes? The Artificial Intelligence (AI) – Judicial Guidance (October 2025) provides a helpful explanation:
“AI tools are now being used to produce fake material, including text, images and video. Courts and tribunals have always had to handle forgeries, and allegations of forgery, involving varying levels of sophistication. Judges should be aware of this new possibility and potential challenges posed by deepfake technology.”
The question of prevalence is more difficult. Deepfakes are becoming increasingly realistic and increasingly accessible. That is part of the difficulty. If a fabrication is not obvious, how will a court, lawyers or litigants detect it? In an earlier article I discussed the importance of CPR 32.19 as a procedural safeguard for documentary authenticity. That rule remains significant, but we will need to think more broadly across other areas of law. As we all must remain alert to the risks.
To assist with that aim, I have created an International AI Deepfake Database and Tracker to record how deepfake material is being used and cited in court proceedings across the world. At present there are eleven entries, although I am aware of others that will be added. If you come across any cases that are not yet included on the tracker, I would be very grateful if you would send them to me. In the same way that colleagues have generously shared hallucination decisions, which has strengthened the accuracy and usefulness of that database, contributions here will benefit us all. The more complete the picture, the better equipped we are as a profession to respond thoughtfully and proportionately.
When I began tracking hallucination cases, the numbers were modest. They grew quickly. I anticipate a similar trajectory here and I suspect that by the end of the year the volume internationally may be considerable, if it is not already.
In relation to hallucinations in the UK, my research is ongoing. I have identified several additional UK cases, all arising in the Employment Tribunal. That brings my current tally to forty seven. The issue is not confined to fictional authorities. The Tribunal appears to be grappling with expanding bundles, increasingly lengthy AI generated documents, the strain on judicial time and resources, and in at least one case the risk that AI assisted drafting may have contributed to confusion about a litigant’s intended procedural position. These developments merit careful and measured attention from all of us working in this space.
Green v Imprint Creative Print Solutions LTD
Read more at
