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The English High Court has referred a litigant to the Attorney General over falsified evidence after he blamed an artificial intelligence tool for producing a fabricated calendar exhibit
Almost every AI case in the courts so far has been about fabricated citations. This one is about a fabricated exhibit. The document was a screenshot of a university calendar, and the court noticed it showed two Tuesdays in the same week.
Bottom line: Mr Justice Linden referred the matter to the Attorney General's Office to consider contempt proceedings and a possible police referral, identifying four categories of potential criminal contempt. He also referred the claimant's barrister and his chambers to the Bar Standards Board, and held that restraints on the claimant's litigation activity must be a matter of public record.
Who this affects: Litigators and their clients in England and Wales, anyone signing a statement of truth, firms setting policy on AI-assisted drafting of evidence, and barristers and solicitors weighing their duties when a client's exhibit is questioned.
Issue date: Handed down 24 July 2026. It follows the court's first judgment of 18 May 2026, [2026] EWHC 1177 (KB), which dealt with costs after the claimant discontinued his claim.
What changed: No new rule. The significance is the category: this is AI offered as an explanation for falsified documentary evidence rather than for a bad citation, and the court treated the explanation as part of the conduct rather than as mitigation.
Analysis: The timing is what defeated the explanation. The AI account first appeared in an amended witness statement filed eleven days after a university lecturer's statement had exposed the problem. The judge had already found that an earlier email was laying a paper trail because the claimant had realised his falsification of evidence had been, or was likely to be, discovered.
Primary sources: Judgment, [2026] EWHC 1889 (KB), Find Case Law · First judgment, [2026] EWHC 1177 (KB)
- Case
- Amar Lodhia v (1) Twelve Trees (Bromley-By-Bow) Management Company Limited (2) Urang Property Management Limited (3) Mr Thomas Squires (4) Mr Andrew Cregan (5) Mr Tasleem Malleck-Amode
- Neutral citation
- [2026] EWHC 1889 (KB); Case No. KB-2025-001785
- Court
- High Court of Justice, King's Bench Division, Media and Communications List, Royal Courts of Justice
- Judge
- Mr Justice Linden
- Representation
- The Claimant appeared in person. Jonathan Price KC and Percy Preston, instructed by rradar Limited, for the Defendants.
- Jurisdiction
- England and Wales
- Status
- Judgment handed down 24 July 2026. Referral made to the Attorney General's Office; referral made to the Bar Standards Board.
- Bindingness
- A first-instance judgment of the High Court. Binding between the parties; persuasive in later cases.
- Related judgment
- [2026] EWHC 1177 (KB), 18 May 2026, on costs following discontinuance
- Editorial Note
- Informational analysis for working professionals, not legal advice. Confirm how any rule applies to your situation with qualified counsel.
- Primary source
- https://caselaw.nationalarchives.gov.uk/ewhc/kb/2026/1889
The exhibit, and the detail that gave it away
The underlying claim had already been discontinued. What remained were costs and conduct, and within that a question about whether a court hearing had been rescheduled to accommodate the claimant's law-school assessment.
The document at the centre of it was a calendar image, exhibited in evidence, depicting a Criminal Law assessment on 6 May 2026. The judgment records the feature that made it impossible: the calendar entry had two Tuesdays in the same week.
The problem surfaced through a third party. Ms Saloumeh Verrell, a Senior Lecturer at the University of Law, provided a witness statement dated 15 May 2026. The judgment also records that Dr Myrto Tsakopoulou of East London NHS Foundation Trust had been ordered to provide statements because there were concerns about the authenticity of certain documents which the claimant presented as having been prepared by her.
Before that, the judge found, the claimant had sent Ms Verrell a set of edited documents and a statement he had drafted for her which fudged the rescheduling point, to maximise his chances that she would not realise the court had been misled. In the judge's words, this attempt to sweep the matter under the carpet was unsuccessful.
The AI explanation, and why it failed
The artificial intelligence account appears in an amended version of the claimant's seventeenth witness statement, submitted on 26 May 2026. The judgment notes precisely when that was: eleven days after Ms Verrell's witness statement.
The explanation given was that at the time the AI-assisted draft was prepared he honestly believed the assessment was scheduled for 6 May 2026, that this honest but mistaken belief was the basis of the instruction, or prompt, entered into the artificial intelligence tool, and that this was why the tool generated, in error, the calendar image and exhibit depicting an assessment on that date.
The court did not accept it. Linden J had already found that an earlier email was not evidence of genuine belief but an attempt at laying a paper trail because the claimant had realised that his falsification of evidence had been, or was likely to be, discovered. The judge said in terms of a related explanation that it does not make sense and I do not believe it.
The judgment does not name the tool, and nothing in it turns on which tool was used. That is worth noting precisely because the explanation was structural rather than technical: the claim was that a prompt reflecting a mistaken belief produced a mistaken image. The court's answer was about sequence and credibility, not about model behaviour.
What the court referred, and to whom
On contempt, the judge concluded that the matter should be referred to the Attorney General's Office for consideration of whether to proceed against the claimant for contempt of court and, or alternatively, to refer the matter to the police.
Without tying the hands of the Law Officers, the judgment sets out four categories of potential criminal contempt found on the evidence: knowingly making false statements in witness statements verified by a statement of truth, citing CPR rule 32.14; knowingly making false statements in other court documents, specifically statements of costs and certificates of service; doctoring a court order, citing Dryer v HSBC Bank plc [2014] EWHC 3949 (Ch); and falsifying documentary evidence, citing Cole v Carpenter [2020] EWHC 3155 (Ch).
The judgment adds that the Law Officers may also wish to consider civil contempt proceedings based on failure to comply with the court's orders of 29 April and 18 May 2026.
Separately, the judge referred the claimant's barrister, Mr Chiffers, and Joseph Chiffers Barrister at Law Limited, trading as JSC Chambers, to the Bar Standards Board for investigation of concerns addressed in both judgments, saying he did not have confidence that Mr Chiffers had matters in hand.
The defendants had told the court they believed the claimant was guilty of contempt in various respects but, for cost-related reasons, were not themselves prepared to make a committal application. Their position was that the court should act of its own motion or refer the matter to the Attorney General. That is the route the judge took.
Why this is a different case from the citation cases
The body of AI case law that has built up over the last three years is overwhelmingly about legal research: fabricated authorities, misquoted holdings, briefs assembled from cases that do not exist. The professional duty at issue is verification of law.
This case is about evidence. The document was not a citation but an exhibit going to a contested question of fact, tendered in support of a witness statement verified by a statement of truth. That engages CPR rule 32.14 and the law of falsifying documentary evidence rather than the duty to check authorities.
The practical difference for a litigator is where the exposure sits. A fabricated citation is usually discoverable by the opponent or the court through ordinary legal research. A fabricated exhibit may only be discoverable through a third party who knows the underlying facts, which is what happened here, or through an internal inconsistency such as a week containing two Tuesdays.
It also changes what an AI-use policy has to cover. A policy that requires authorities to be verified says nothing about whether a generated image, screenshot, chart or reconstruction may be exhibited as a record of something that happened.
Restraint, and the public record point
On restraining further litigation, the judge rejected the sufficiency of a confidential undertaking. He held that it is very important that the restraints on the claimant's litigation activity should be a matter of public record, and that a confidential undertaking would be very unlikely to be effective given the history set out in the judgment.
On costs, the judge accepted that the defendants were wholly successful at the 6 May hearing and that costs should follow the event, rejecting the argument that the defendants' own conduct justified a reduction and finding that it was the claimant's conduct in taking a number of hopeless points that had increased costs.
The claimant had also asked the court to initiate contempt proceedings against the defendants' solicitor, Ms Yates, and to refer her and rradar Limited to the Solicitors Regulation Authority under the Hamid jurisdiction. The judgment records those applications among the matters it disposed of.
Treat this as the case that extends AI risk from citations to exhibits. Three things carry over. An AI explanation offered after the problem has been exposed will be assessed on its sequence: this one arrived eleven days after the witness statement that surfaced the discrepancy, and the court read it alongside an earlier finding that the litigant was laying a paper trail. The consequences attach to the statement of truth rather than to any AI-specific rule, which means CPR rule 32.14, contempt, and referral to the Law Officers and the police are all live without any new regulation. And if your AI policy only requires authorities to be checked, it does not yet address the document that caused this case, because nobody verifies a calendar screenshot the way they verify a citation.
Source File
https://caselaw.nationalarchives.gov.uk/ewhc/kb/2026/1889
Open the judgment and confirm four things: the neutral citation [2026] EWHC 1889 (KB) with Case No. KB-2025-001785 and the date 24/07/2026 in the header; Mr Justice Linden named as the judge; paragraph 116, which reproduces the claimant's account of the AI-assisted draft and the prompt; and the section headed Contempt of court at paragraph 261, which makes the referral to the Attorney General's Office and lists the four potential criminal contempts.
In the light of my findings about the conduct of Mr Lodhia, I have concluded that this matter should be referred to the Attorney General's Office for consideration of whether to proceed against him for contempt of court and/or to refer the matter to the police. Lodhia v Twelve Trees (Bromley-By-Bow) Management Company Ltd, [2026] EWHC 1889 (KB) at [261]
FAQ
What did the AI actually produce?
A calendar image, exhibited in evidence, depicting a Criminal Law assessment on 6 May 2026. The claimant's account was that a prompt reflecting his mistaken belief about the date caused the tool to generate the image in error. The judgment records that the calendar entry showed two Tuesdays in the same week.
Did the court accept the AI explanation?
No. It arrived in an amended witness statement filed eleven days after the lecturer's witness statement that exposed the discrepancy, and the judge had already found that the claimant's earlier email was laying a paper trail because he had realised his falsification of evidence had been, or was likely to be, discovered.
Which AI tool was it?
The judgment does not name it, and nothing in the reasoning turns on which tool was used.
What are the four potential criminal contempts?
Knowingly making false statements in witness statements verified by a statement of truth under CPR rule 32.14; knowingly making false statements in other court documents, namely statements of costs and certificates of service; doctoring a court order; and falsifying documentary evidence. The judgment cites Dryer v HSBC Bank plc [2014] EWHC 3949 (Ch) and Cole v Carpenter [2020] EWHC 3155 (Ch).
Was anyone else referred?
Yes. The judge referred the claimant's barrister, Mr Chiffers, and Joseph Chiffers Barrister at Law Limited, trading as JSC Chambers, to the Bar Standards Board, stating that he did not have confidence that Mr Chiffers had matters in hand.
Why did the court, rather than the defendants, raise contempt?
The defendants contended the claimant was guilty of contempt in various respects but, for cost-related reasons, were not prepared to bring a committal application themselves. They asked the court to act of its own motion or refer the matter to the Attorney General, and the judge referred it.
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