Artificial Intelligence is being increasingly used by clients attempting to reduce their reliance on lawyers, and in some cases by lawyers themselves in legal research.  In a US decision of Mata v Avianca Inc (2023), submissions were prepared using Chat GPT, citing a number of court decisions, and these submissions were provided to the court. 

Unfortunately, a number of the decisions supplied by Chat GPT in support of the submissions – and quoted in the submissions – did not exist.

This experience is to some extent consistent with our observations when reviewing material created by third parties utilising Artificial Intelligence.  To some extent, a reader is lulled into a false sense of security as the material is quite often very well written, however it can have critical errors – such as a reliance on a statutory provision which no longer exists. 

The circumstances of Mata v Avianca Inc [2023] are a timely caution that when it comes to the use of Artificial Intelligence to prepare documents, one cannot be confident that the content is accurate or the sources quoted are current or exist. 

If your preference is for documents to be created by a human – and correctly – please contact our commercial and property team, Peter Muller at Jessica Murray at or Megan Sarroff at