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Low reported severity

UK Upper Tribunal: solicitors' ChatGPT-drafted grounds in an asylum appeal cited fake cases and invented quotes; two individuals self-report to the SRA

A published Upper Tribunal (Immigration and Asylum Chamber) decision issued on 21 September 2026 records that the grounds of appeal and skeleton argument in a Namibian national's protection appeal were produced by a paralegal at her then solicitors using ChatGPT. The tribunal recorded her counsel's acceptance that the grounds cited fake cases, quoted passages absent from those judgments and attributed to the First-tier judge sentences he never wrote, and itself called one purported quotation pure invention. The September 2025 error-of-law hearing was adjourned, the appellant later withdrew three of her four original grounds, her remaining and amended grounds were found to disclose no error of law, and the tribunal directed the Home Office to file any wasted costs application against the firm. The decision states that two individuals have reported themselves to the Solicitors Regulation Authority; the Law Society Gazette reported the decision on 8 October 2026.

AI system
ChatGPT
OpenAI
Occurred
17 Sept 2025 to 21 Sept 2026
Reported
6 October 2026
Event location
United Kingdom
What the AI did
Acted on the person’s behalf · Informed a human decision about the person
Reported harm
Legal HarmProfessional Harm
Whose AI use
Someone else’s AI use
Setting
Justice
Evidence
AI involvement supported · Causal attribution established · 2 sources, 1 underlying account
5 claims: 5 documented. 5 open questions
People reported harmed
At least 1 person

AI system as recorded: ChatGPT, used by a paralegal to generate grounds of appeal and a skeleton argument (as found in the Upper Tribunal decision)

Reported harm

The tribunal records that the appellant's error-of-law hearing in September 2025 was adjourned, that three of the five issues at the eventual hearing, which occupied a great deal of its time, arose only because of her solicitors' inappropriate use of AI, that she withdrew three of her four original grounds, and that her appeal fails. The decision states that two individuals have reported themselves to the Solicitors Regulation Authority and directs the Home Office to file any wasted costs application against the firm; no costs decision has been taken.

What remains unknown

  • The date on which the paralegal generated the grounds of appeal is not stated; it falls between the First-tier decision of 23 April 2025 and the hearing listed for 17 September 2025.
  • Whether the two individuals who self-reported to the Solicitors Regulation Authority are the paralegal and the supervising solicitor is not stated, and the outcome of any SRA consideration is unknown.
  • Whether the Home Office pursued wasted costs, and any amount, was not decided in the published decision.
  • What prompts were given to ChatGPT, and whether client material was entered into it, is not described; the tribunal only notes that the use raises confidentiality and privilege concerns.
  • Whether the appellant's appeal would have succeeded on properly drafted grounds cannot be known; the tribunal found the surviving and amended grounds disclosed no error of law.

What the evidence supports

AI involvement: supported. The Upper Tribunal's published decision finds that the grounds of appeal and the skeleton argument filed on the appellant's behalf were produced by a paralegal using ChatGPT, and describes what that output contained: citations of fake cases, paragraphs not found in the cited judgments, and purported quotations from the First-tier judge's decision that the tribunal calls pure invention. The decision connects that output to the harm: the September 2025 hearing was adjourned after the Home Office queried the citation errors, three of the five issues at the final hearing, which occupied a great deal of its time, arose only because of the solicitors' use of AI, the appellant withdrew three of four grounds, and the tribunal invited a wasted costs application and noted two self-reports to the regulator. The FtT judge granted permission on those grounds while noting the misquotations, and the Upper Tribunal's decisions not to set aside permission and to refuse the new grounds were taken in the express context of the misrepresentations. The tribunal itself states that the irregularities were caused by the solicitors' misuse of AI rather than by AI, and the decision records the solicitors' own acceptance that AI was used. The firm's acceptance and the tribunal's findings come from one record, so the status is supported rather than corroborated by an independent source.

5 claims: 5 documented. What the statuses mean

Documented The appellant's then solicitors drafted grounds of appeal that her counsel accepted were completely infected by the use of AI, citing fake cases and paragraphs not contained in the cited judgments and quoting passages from the First-tier Tribunal decision that do not appear in it; the tribunal found one purported quotation to be pure invention.

Causal attribution. Established by the tribunal's own findings and its record of counsel's concession in the published decision. The Gazette repeats the decision and adds no independent origin.

  • tribunalsdecisions.service.gov.uk(opens in new tab) supports · English
    the grounds of appeal were completely infected by the use of AI. In addition to the citation of fake cases, and paragraphs from cases which are not contained in those judgments, the Grounds of Appeal also quote paragraphs from the decision of the First-tier Tribunal which do not appear in that decision.
  • tribunalsdecisions.service.gov.uk(opens in new tab) supports · English
    This was pure invention, which was not to be found anywhere in Judge Balroop’s decision, yet criticism of it formed the basis for one aspect of ground (3) in the grounds of appeal.
  • tribunalsdecisions.service.gov.uk(opens in new tab) supports · English
    In this case, Mr Badar identified at least 18 separate errors in the grounds of appeal and withdrew three of the four grounds.
Documented The tribunal found that both the grounds of appeal and the skeleton argument were produced by a junior member of staff, a paralegal, using ChatGPT, and that the firm did not check their accuracy; the solicitors had accepted that AI was used to generate both documents.

Causal attribution. The product identification and the failure to check are the tribunal's findings in the decision, recorded with the solicitors' acceptance that AI generated the documents. The Gazette's statement that the drafter was an unnamed paralegal relays the decision (same independence group).

Documented The error-of-law hearing listed for 17 September 2025 was adjourned, three of the five issues at the final hearing, which occupied a great deal of its time, arose only because of the solicitors' use of AI, the appellant withdrew three of her four original grounds, and her appeal failed after her remaining and amended grounds were found to disclose no error of law.

Causal attribution. Procedural history and disposition are directly established by the decision. The decision attributes the adjournment and the wasted hearing time to the solicitors' misuse of AI, and states separately that the surviving ground failed on its merits, so the dismissal itself is not attributed to the AI output.

Documented The decision states that two individuals have reported themselves to the Solicitors Regulation Authority, and directs the Home Office to file any wasted costs application against the firm within 28 days; no costs decision has been taken.

Causal attribution. The self-reports and the costs directions are stated in the decision itself. The Gazette repeats them from the decision (same independence group), so the claim is documented, not corroborated. Whether the two individuals are the paralegal and the supervising solicitor is not stated.

  • tribunalsdecisions.service.gov.uk(opens in new tab) supports · English
    Two individuals have reported themselves to the Solicitors Regulation Authority and so we will say nothing about the professional conduct issues involved.
  • tribunalsdecisions.service.gov.uk(opens in new tab) supports · English
    The respondent shall file and serve on Sarker Solicitors any wasted costs application, or confirmation that costs are not being pursued, within 28 days of this decision being sent to the parties.
  • lawgazette.co.uk(opens in new tab) supports · English
    Two individuals involved in filing court documents using ChatGPT which were riddled with mistakes and invented quotes have reported themselves to the Solicitors Regulation Authority.
Documented The tribunal said it would be misleading to describe the irregularities as caused by AI rather than by the solicitors' misuse of AI, while describing the case as one of the more extreme examples of the misuse of AI.

Causal attribution. The tribunal's own qualification, preserved as contrary evidence on causation: the decision places responsibility with the solicitors, and the Home Office's characterisation (at best negligent, at worst reckless) is relayed in the decision as a submission.

Sources

2 sources inspected, from 1 underlying account. Sources that repeat one account do not corroborate each other.

How the sources were read, and where the events happened

Event countries: United Kingdom. Affected-person countries: United Kingdom. Court countries: United Kingdom.

The decision is an Upper Tribunal (Immigration and Asylum Chamber) decision heard at Field House, London, in an appeal against a UK Home Office refusal; the solicitors are described by the Gazette as an east London firm. The appellant is a Namibian national whose appeal concerns her removal from the UK, so her country is recorded as GB on the basis of the proceedings in which she was harmed, and Namibia is not recorded because no harm occurred there.

Reviewed for publication 2026-10-09: The published Upper Tribunal decision (tribunalsdecisions.service.gov.uk, UI-2025-002601) and the Law Society Gazette report of 8 October 2026 were read in full on 2026-10-09. The decision records what ChatGPT generated (fake cases, misattributed paragraphs, invented quotations from the First-tier judge) and ties that output to the adjourned hearing, the wasted hearing time, the withdrawn grounds, the regulator self-reports and the costs directions. The appellant is anonymised by tribunal order and is described only by nationality and appeal type; the firm is named because the operative costs directions are addressed to it; the paralegal is unnamed. The tribunal's statement that the solicitors' misuse, not AI, caused the irregularities is preserved.

People described

A Namibian national pursuing a protection and human rights appeal in the United Kingdom, anonymised by tribunal order, whose solicitors filed AI-generated grounds of appeal on her behalf

People reported harmed in this case

At least 1 person

0 AI participants · 1 other person harmed

One person counted: the appellant, whose appeal proceeded on AI-generated grounds she did not draft (the decision describes her as the appellant throughout). The paralegal who used ChatGPT and the supervising solicitor face professional consequences of their own conduct (self-report to the SRA, possible wasted costs) and are not counted as harmed persons; the two self-reporting individuals are not named as the paralegal and the solicitor in the decision.

Counted once within this case. The same person may appear in other cases. This count does not establish AI causation.

Cite this case

Compiled per our published methodology: verification statuses, sourcing standards, and corrections process.

APA

NOPE. (2026). UK Upper Tribunal: solicitors' ChatGPT-drafted grounds in an asylum appeal cited fake cases and invented quotes; two individuals self-report to the SRA. AI incidents. https://nope.net/incidents/2025-uk-upper-tribunal-asylum-appeal-chatgpt-grounds-fake-cases-invented-quotes-sra-self-report

BibTeX

@misc{2025_uk_upper_tribunal_asylum_appeal_chatgpt_grounds_fake_cases_invented_quotes_sra_self_report,
  title = {UK Upper Tribunal: solicitors' ChatGPT-drafted grounds in an asylum appeal cited fake cases and invented quotes; two individuals self-report to the SRA},
  author = {NOPE},
  year = {2026},
  howpublished = {AI incidents},
  url = {https://nope.net/incidents/2025-uk-upper-tribunal-asylum-appeal-chatgpt-grounds-fake-cases-invented-quotes-sra-self-report}
}

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