In 2023, a lawyer in New York asked ChatGPT to find case law for him. The chatbot gave him several cases. None of them existed. The judge fined the lawyers 5,000 dollars and called part of their filing gibberish.
That case, Mata v. Avianca, became a warning for lawyers all over the world. It matters in Pakistan too. Pakistani courts decide cases on written arguments and cited precedents. One fake citation can mislead a judge and waste months of a person's time.
What actually happened in the Avianca case
Roberto Mata said an Avianca crew member hit his knee with a metal serving cart during a flight. He sued the airline in New York in 2022. His lawyers used ChatGPT to draft a court filing. The chatbot invented several cases, complete with quotations that looked real.
The airline's lawyers told the court they could not find those cases. The judge could not find them either. When the plaintiff's lawyers asked ChatGPT about it, the chatbot insisted the cases did exist and could be found in legal databases like LexisNexis and Westlaw. That was false.
In June 2023, Judge P. Kevin Castel fined the lawyers 5,000 dollars. He found they had acted in bad faith, and he described one piece of their analysis as gibberish. The full order is published here.
It was not a one off mistake
An online database run by Damien Charlotin tracks cases where AI was used to cite fake law. It now records over 800 documented instances. A judge in Minnesota quoted that number in a 2026 order.
In the United States, a Minnesota lawyer cited two cases that did not exist in a rent dispute. One was an invented 1948 case called Anderson v. City of Biwabik. The judge fined him 5,000 dollars, and he agreed to a 30 day suspension of his licence. The Minnesota Supreme Court used the incident to remind lawyers that their ethical duties apply no matter which tool they use.
In England, a barrister cited fictitious cases in an immigration hearing and then tried to hide that he had used AI. The tribunal caught him in October 2025.
In India, the Supreme Court in March 2026 raised the alarm after a judge decided a property dispute using fake AI generated orders. The Court had already flagged lawyers who file AI drafted petitions with fake citations, and it took a zero tolerance position.
What Pakistan has done so far
In March 2023, a judge in Punjab tried ChatGPT for himself. Additional District and Sessions Judge Mohammad Amir Munir sits in Phalia, in Mandi Bahauddin district. He was hearing the bail plea of a 13 year old boy accused of kidnapping and attempted rape. He asked the chatbot whether it could cite case law where bail is allowed in such cases. He put the chatbot's answers into his order and called them impressive. But he wrote clearly that his decision was not based on those answers. It was based on his own reading of the law. He granted bail against surety bonds of 50,000 rupees.
In March 2025, the Supreme Court of Pakistan spoke about AI in Ishfaq Ahmed v. Mushtaq Ahmed, a tenancy dispute between two brothers that had dragged on for seven years. The Court noted that over 2.2 million cases were pending in Pakistani courts. It said AI can help courts work faster, but only as an auxiliary tool. It cannot replace human reasoning. The judgment was delivered by Justice Syed Mansoor Ali Shah.
In February 2026, the National Judicial Policy Making Committee approved the National Guidelines for Use of AI in Judicial Institutions of Pakistan. The guidelines say AI must not replace the final decision of a judge. A judge must record independent reasoning. Any part of a document produced by AI must be identifiable, with references, and the user must explain how it was verified. The guidelines prefer locally developed AI trained on Pakistani legal data.
What is missing so far is a rule for lawyers. As of early 2026, the Pakistan Bar Council had issued no guidelines on lawyers using AI, and no High Court had issued practice directions for the bar.
Why a fake citation is dangerous in a Pakistani court
In Pakistan, a precedent only counts if it exists. A statute only says what its text says. A polished paragraph from an AI tool carries no authority on its own.
If a lawyer files a case that does not exist, the court or the other side will eventually check. When that happens, the lawyer's credibility drops and the client pays the price in time and trust. Even online write ups mix up legal sections. We corrected one example in our guide to cheque bounce in Pakistan, where the correct offence is section 489-F of the Pakistan Penal Code, not the section many websites mention.
How to check a citation yourself
You do not need to be a lawyer to do a basic check. Five steps.
- Ask for the full citation. A real Pakistani citation names the court, the year and the report page. For example, PLD 2025 SC 582.
- Read the judgment itself. The Supreme Court and the High Courts publish many judgments online. You can even check a high court case status online in Pakistan.
- Check the statute text against an official source. Laws are available on official portals like pakistani.org and provincial law sites.
- If you cannot find the case anywhere, treat it as a red flag. Ask where it was reported.
- If your lawyer gives you a case name, ask to see the judgment. A good lawyer is happy to show you.
What this means for you
AI tools are useful. They can summarize, draft and translate fast. But someone must verify what they say before it goes near a court.
If you use a legal AI, prefer one that shows the source behind every answer, so you can check it yourself.
If you have a real case, get a real lawyer. If you cannot afford one, free legal aid in Pakistan exists for people who qualify.
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