Last week, the Supreme Court of Zimbabwe issued a landmark ruling declaring invalid legal submissions prepared with the help of artificial intelligence (AI) that included fictitious case citations.
The ruling arose from the Pulserate Investments (Pvt) Ltd v Andrew Zuze and Others [SC202/25] case, in which the appellant’s heads of argument, filed by Professor Welshman Ncube, were found to include 12 non-existent cases generated by AI.
In its judgment, the Court held that the defective submissions carried no legal weight and could not be salvaged.
The bench, comprising Justices Susan Mavangira, Felistus Chatukuta, and Hlekani Mwayera, dismissed Pulserate Investments’ appeal and ordered the company to bear the costs.
The ruling came after Advocate Thabani Mpofu, representing Andrew Zuze, challenged the submissions.
The case drew attention after it emerged that Professor Ncube’s filings contained fictitious citations generated by AI. In a letter to the Supreme Court, submitted earlier this year, Professor Ncube apologised, admitting failure to verify the research which was prepared by a graduate assistant who had relied on artificial intelligence.
The case underscores the growing risks of unverified use of artificial intelligence in legal research without proper oversight.
It will act as a cautionary example for the legal profession on the importance of vigilance, meticulous verification, fact-checking, accountability and the strategic necessity of human in the loop when adopting emerging technologies in legal practice.
Legal experts said the superior court’s rejection of the submissions underscores the importance of professional diligence and the accuracy of legal arguments presented before the bench.
While AI presents opportunities to enhance legal research, improve consistency in judgments, and expand access to justice, its unchecked use can seriously compromise the integrity and accountability of the legal sector.
AI must support, not replace, human judgment and ethical reasoning in legal research.
Considering this, MISA Zimbabwe calls upon the Law Society of Zimbabwe and other relevant stakeholders to develop a Guideline or Policy Framework governing the responsible use of AI in the legal sector.
The framework should be grounded in principles of accountability, transparency, fairness, and mandatory human oversight, ensuring alignment with constitutional values and the rule of law.
Furthermore, this will test the recently adopted Zimbabwe National AI Strategy 2026 – 2030, which should define the country’s risk appetite in the development, adoption, and deployment of AI solutions permeating through the entire architecture of society.
MISA Zimbabwe Communique
