An unescaped &
sign is an error. So the solution is to escape all the &
signs.
<input type="hidden" name="return_url"
value="index.php?option=com_content&view=article&id=9&Itemid=&lang=en&msgsent=1" />
This works in HTML as well as XHTML.
Note: HTML has different error recovery methods than XHTML, which causes the error to be not as bad a problem in HTML as in XHTML. It's still an error though!