Resources

The use of AI from the Irish Court of Appeal

Articles & Publications
13 April 2026

An interesting decision on the use of AI from the Irish Court of Appeal (see paragraphs 72-76) – with potentially quite radical consequences.

The defendant litigant in person used AI to prepare the written submissions filed in support of her (unsuccessful) appeal. The submission referred to non-existent authorities, and she appeared not to have verified the existence of the authorities, or whether they supported the propositions advanced.

The court noted that all parties had an obligation not to mislead the court, and expressed the view that parties should “use AI appropriately and should be given guidance as to how they may properly use AI in their litigation”.

The following were said to be “principles of general application”:

  • Parties are entitled to use AI to assist in carrying out research in respect of their case provided that they do so responsibly and do not, even inadvertently, mislead the court by advancing propositions or relying upon supposed authorities which in fact have no foundation at all and are simply hallucinations.
  • In all cases where they do so, they should expressly inform both the other parties and the court of their use of AI in this regard.
  • A self-represented party is responsible for the ultimate written or oral work in their case just as much as the lawyers representing parties are.
  •  It is important therefore that any party who uses AI as part of their research independently verifies the accuracy of their submissions and the authorities cited as supposedly establishing the propositions advanced.
  • No authority should be cited by a party who has not actually verified that it is a genuine judgement of the court and that it is – or at least arguably is – authority for the proposition contended for.

Most of these points are unobjectionable – but the second could have far-reaching consequences. Unusually, it requires any use of AI for “research” to be disclosed. This goes even further than some of the most restrictive court guidance internationally (see e.g. the Federal Court of Canada) which tends to focus on the use of AI to ‘generate’ text for submissions.

How much detail must be given in such declarations? What impact will/should this have on the court’s decision-making? How will it affect the take-up of AI tools in the legal profession? Plenty to think about for both the lawyers and litigants and person subject to these new rules.

To read more AI related content, please visit our AI Hub.

Related People

John Williams

Call: 2017

Search

Expertise

Related resources

BSB Guidance on the use of AI and Other Technologies


On 18 May 2026, the BSB published its Guidance on the use…

Discover more

Providence and party intention: the Supreme Court on industry-wide standard forms


Alex Forzani and Teen Jui Chow have published an article examining the…

Discover more

Know Thy Tools: the FRC’s Guidance on Generative and Agentic AI


On 30 March 2026, the FRC published guidance to support audit firms…

Discover more

If you would like to know more or have a question please talk to our clerks

Portfolio Builder

Select the expertise that you would like to download or add to the portfolio

Download    Add to portfolio   
Portfolio
Title Type CV Email

Remove All

Download


Click here to share this shortlist.
(It will expire after 30 days.)