The Supreme Court of Zimbabwe has ruled that legal submissions prepared with the assistance of artificial intelligence by Professor Welshman Ncube are invalid after it was discovered that they cited 12 fictitious judgments.
The court declared that the submissions, filed on behalf of Pulserate Investments in a mining dispute with Andrew Zuze, held no legal effect and should be treated as a nullity. The ruling followed an objection raised by Advocate Thabani Mpofu, who represented Zuze in the matter.
Pulserate Investments had been represented by Professors Welshman Ncube and Lovemore Madhuku. The two argued that despite the errors, the defective submissions could still be considered. However, the bench comprising Justices Susan Mavangira, Felistus Chatukuta, and Hlekani Mwayera dismissed this argument.
Justice Mavangira ruled that the documents could not stand as part of the record, affirming Advocate Mpofu’s position that the submissions had no legal foundation. “The court has the power to erase these documents as of no consequence,” she stated.
In the same ruling, the court dismissed Pulserate’s appeal by consent of both parties, noting that it was effectively abandoned. The company was also ordered to pay Advocate Mpofu’s costs on the higher scale. “The matter is hereby removed from the roll, regarded as abandoned and deemed dismissed,” Justice Mavangira ruled.
The controversy arose after it was discovered that the submissions contained multiple fabricated and defective case citations. Following this revelation, Prof Ncube wrote a formal letter to the Supreme Court on July 3, expressing regret and taking responsibility for the errors. “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 the appellant in this matter,” he wrote.
Prof Ncube explained that the mistakes originated from a graduate researcher he had assigned to conduct legal research. The researcher, he said, had relied on artificial intelligence tools to find case law without verifying the authenticity of the information. “Upon reviewing the respondent’s submissions, I questioned my researcher, who admitted to using artificial intelligence for research and failing to verify the material it provided,” he said.
He denied any intention to mislead the court, describing the situation as a “catastrophic lapse in professional judgment.” In his letter, Prof Ncube acknowledged that he had trusted the researcher’s work without conducting his own checks. “It is difficult to imagine anything more embarrassing to me personally as senior counsel and officer of this honourable court,” he wrote. “The integrity of all legal proceedings depends on the accuracy of authorities cited.”
Prof Ncube also extended his apology to Advocate Mpofu for the inconvenience caused by having to verify the non-existent cases. “I humbly submit this apology to the court and to counsel for the first respondent, who had to endure the agony of verifying these non-existent and defective cases,” he wrote.
The case, Pulserate Investments (Pvt) Ltd v Andrew Zuze and Others [SC202/25], has drawn attention to the growing risks of using artificial intelligence in legal work without adequate human oversight. Legal analysts said the ruling serves as a cautionary reminder that professional diligence and accuracy remain central to the integrity of court proceedings.
