Zimbabwean Lawyer Issues Apology After AI-Generated Fake Case Law Cited in Supreme Court Filing
Welshman Ncube apologized for submitting a Supreme Court brief with fabricated case law generated by AI tools. He took full responsibility, citing a failure to verify the references.

Welshman Ncube Issues Apology for AI-Generated Errors in Supreme Court Filing
Welshman Ncube, a prominent opposition politician and experienced lawyer, has formally apologized to the Supreme Court of Zimbabwe after a legal brief he directed contained fabricated and misinterpreted case law. The errors stemmed from reliance on artificial intelligence (AI) tools that produced inaccurate references.
Details of the Case and Errors
The issue arose in the matter of Pulserate Investments (Pvt) Ltd v Andrew Zuze and Others [SC202/25], where Ncube represented the appellant. The filing submitted listed twelve cases that were either fictitious or irrelevant to the legal points argued.
In a letter dated 3 July 2025 to the Registrar of the Supreme Court, Ncube accepted full responsibility for these mistakes. He explained that the flawed citations originated from research conducted by a graduate assistant who used AI tools without verifying the authenticity of the cases cited.
Extract from Ncube’s Apology Letter
"I write to request that you kindly place this letter of apology before their Lordships before whom the above matter will be placed for adjudication. I wish to express my profound regret and apology to the Court for the citation of defective and non-existent cases in the Heads of Argument I prepared and caused to be filed on behalf of Appellant in this matter."
He further acknowledged that the failure to check the accuracy of AI-generated case law was a serious oversight on his part, stating:
"It never occurred to me that it was possible for a graduate researcher to present to me non-existent and defective case law authorities given the training we go through as lawyers and hence my negligent failure to check the authenticity of the cases."
Clarifying Intent and Professional Responsibility
Ncube emphasized that the errors were unintentional and not meant to mislead the Court or prejudice any party. Instead, he described them as a significant lapse in professional judgment.
He wrote:
- These errors were not deliberate or motivated by any intention to mislead the Court.
- The integrity of legal proceedings depends on accurate citation of authorities.
- The matter involves substantive legal issues that deserve proper consideration without distraction from incorrect case citations.
Ncube expressed personal embarrassment over the incident and extended his apology to the Court and opposing counsel who had to verify the incorrect references.
Lessons for Legal Professionals Using AI Tools
This incident highlights the risks inherent in relying on AI-generated research without adequate verification. While AI can be a useful tool for legal research, it requires careful cross-checking to ensure accuracy and reliability.
Legal practitioners should maintain rigorous standards for validating case law and other authorities, regardless of the source. This case serves as a reminder that professional responsibility includes verifying all cited materials before filing.
For legal professionals interested in improving AI literacy and research accuracy, training resources are available that focus on best practices for integrating AI tools safely into legal workflows. You can explore relevant courses and certifications at Complete AI Training.