Litigants in Person (LIPs) often struggle to navigate the court system, and one of the reasons is the difficulty of finding reliable legal information. Another is perhaps the distracting and confusing availability of unreliable information, something AI chatbots have not necessarily improved.

Instances of self-represented litigants (as LIPs are sometimes known) citing non-existent cases recommended by Chat GPT have given rise to concerns over the corruption of the common law with fake precedents. One would hope by now that the judiciary at least would be sufficiently aware of the risk to ensure that any precedent they rely on in a future decision must be one that they have checked not only exists but says what it is relied upon to have said. But even if qualified advocates (some of whom have tripped up in the past) should now be more savvy, it remains a trap for the unwary lay person or LIP. 

Now Sally McLaren, assistant librarian at Inner Temple, has addressed both these problems with admirable thoroughness.

Check your citation

Together with fellow librarian Lily Rowe (now at the Law Society library), she conducted an experiment to see how easy it was to get various publicly accessible generative AI chatbots (Chat GPT, Google Gemini, Microsoft Copilot etc) to discuss a fake citation as though it were a real case, some of them even producing a summary of what it was supposed to have decided (see McLaren S, Rowe L. “You’re right to be skeptical!”: The Role of Legal Information Professionals in Assessing Generative AI Outputs. Legal Information Management. 2025;25(1):19-25. doi:10.1017/S1472669625000052) and Hallucinated case citations, Counsel Magazine, June 2025). 

Then she launched a service by Inner Temple library to check the existence and validity of case citations:  Check My Citation offers to “search leading legal databases and/or print sources to confirm whether your case citation is accurate and legitimate.”

This is not nearly as easy as it sounds, partly because the courts themselves do not keep a comprehensive record of all the judgments that have been given (and many which may be cited as precedents), let alone what was actually said. The situation is improving, thanks in part to the efforts of The National Archives and its free public database, Find Case Law (from which we source the majority of new judgments freely accessible on ICLR.4). Before the days of Neutral Citations, cases were cited by reference to the published law report, but case names and styles of citation have not always been consistent, and depend on sometimes variable elements such as volume numbers, the use of round or square brackets – for (year of judgment) or [year of publication] – and the possibility of two or more short reports appearing on one page (thereby sharing a publication reference). 

Another problem is that even genuine cases may “fall between the cracks.” In the past, they might not be reported, and would thereby be swallowed up in oblivion. And even now, when judgments are routinely published, The National Archives is entirely dependent on the courts and judiciary to send them. They have no powers to demand a copy. And then you get cases which are deliberately hidden by reason of reporting restrictions or, in extreme circumstances, a super-injunction. 

In the absence of any comprehensive database, it is necessary to make a number of checks against different sources, both online and in print. A service that can undertake to do that and to confirm the accuracy of a citation is therefore to be warmly welcomed. The Check My Citation service is available to members of the Inns of Court, who can submit up to five citations a day for checking, via the online form. 

Other information

For those who are not members of the Inns, or even lawyers, McLaren has updated her Guide to Reliable Sources of Legal Information for Litigants in Person (August 2025).  

The guide is organised around key stages: from seeking early legal advice and exploring alternatives to court, to engaging legal representation, considering funding options, and, if necessary, representing yourself. It does not purport to give legal advice, but simply to point the reader to where they can find out what they need to know. Some of the organisations listed can provide advice, from those qualified to give it, while others merely provide information. 

The description “litigant in person” (the judicially approved term, though “self-represented” or “unrepresented” or “pro-se” are also used) suggests a person already engaged in the court process, but there are other options – alternative dispute resolution, mediation etc – and there is information about these too. Should the reader continue down the road to litigation, there is information about finding representation, including free representation from a lawyer acting pro bono, or funded advice via legal aid, insurance, etc. 

If you don’t have a lawyer, you may still seek the assistance in court of a “McKenzie Friend”, who cannot represent you, but can help with taking notes, marshalling paperwork, etc. Among the information about McKenzie Friends is a guide on this website, and there are links to other ICLR content here, including explainers about judgments, case law, legislation, and other topics to be found within our Knowledge section. We appreciate the plug: this content was designed as public legal information and generally assumes no prior specialist knowledge. (If there are other topics we should cover here, we would like to know: all suggestions welcome.) 

There is a clear warning to any LIP who might be tempted to rely on generative AI applications, both about the risk of fabricated citations as well as the risks of material not being up to date, questions of privacy (if you upload details of your problem) and potential bias in the source material.  

As you’d expect from a librarian, McLaren also lists public libraries around the country where law reference materials can be found, as well as academic and specialist libraries which permit some level of public access. For anyone interested enough to take their legal studies beyond resolving their own problem, there is information about law related courses. Finally, there is an A-Z of charities and other organisations that can help. 

While this Guide may be aimed primarily at litigants in person, the amount of useful information and links in it means it would be an extremely useful resource for any lawyer, student or perhaps indeed judge. 

Featured image: Photo by Pixabay, via Pexels.