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Medium reported severity Regulatory Action

UK Upper Tribunal refers a supervising solicitor to the SRA over false citations in judicial review grounds; tribunal records he accepted they were AI-generated

Judicial review grounds lodged in the Upper Tribunal (Immigration and Asylum Chamber) on 26 June 2025 by a solicitors' firm cited four authorities that the judge could not find or that carried wrong citations and propositions. The firm's compliance officer, a solicitor whose name was on the claim form, said a junior fee-earner had drafted the grounds under his supervision; his written explanation named an outdated precedent, practitioner blogs and personal notes as the sources. After a Hamid hearing on 5 November 2025, the tribunal recorded that he accepted the fee-earner had relied on false citations generated by AI, and in a judgment promulgated on 17 November 2025 it referred him to the Solicitors Regulation Authority for the false citations and his failure to supervise. The tribunal said it does not matter how such errors come about. It also announced that the Upper Tribunal judicial review claim form now requires a statement of truth that cited authorities exist and support the propositions they are cited for.

AI system
Unidentified AI tool
Occurred
26 Jun 2025 to 17 Nov 2025
Reported
17 November 2025
Event location
United Kingdom
What the AI did
Informed a human decision about the person
Reported harm
Professional Harm
Whose AI use
Someone else’s AI use
Setting
Justice · Work
Evidence
AI involvement reported · Causal attribution supported · 1 source
6 claims: 4 documented, 2 reported. 4 open questions
People reported harmed
1 person

AI system as recorded: Unidentified AI tool that, according to the tribunal's record of the solicitor's acceptance, generated the false citations a junior fee-earner relied on; no tool is named

What Happened

The grounds. A solicitors' firm lodged judicial review proceedings in the Upper Tribunal (Immigration and Asylum Chamber) on 26 June 2025 with twenty pages of grounds. On 20 August 2025 Upper Tribunal Judge Blundell refused permission and ordered the firm's compliance officer to identify the author of the grounds, because of the authorities cited at four paragraphs: a case given a High Court citation that the judge could not find (the real decision, his own, was an Upper Tribunal case and did not support the proposition), a case cited as a Court of Appeal decision that he could not find, a case given an Administrative Court citation that he could not find under that citation or name, and a case for which no such citation exists.

The explanations. The compliance officer, a solicitor whose name was on the claim form and statement of truth, said a junior fee-earner had drafted the grounds under his supervision. His written explanation of 26 September 2025 said the fee-earner relied on an outdated precedent on the firm's system, practitioner blogs and personal notes, and signed statements from both men suggested an old precedent as the cause. He later told the tribunal he had found and deleted that precedent but could not say what it was. At the hearing on 5 November 2025 he said there was no mechanism by which staff at his firm could use AI; the tribunal answered that anyone with access to Google has access to AI. In discussing other files the fee-earner had worked on, the tribunal wrote that the fee-earner may have relied on false citations generated by AI, as the solicitor accepted he had done in this case.

The referral. The tribunal held that the inclusion of false citations and the solicitor's failure to supervise necessitated a referral to the SRA, adding that his oral evidence strengthened the case for referral. It said it matters not how such citation errors come about, whether inserted by a trainee or by ChatGPT. It also recorded that the Upper Tribunal judicial review claim form has been amended to require a legal representative to confirm by a statement of truth that each cited authority exists, can be located with the citation given and supports the proposition for which it is cited.

Reported harm

The supervising solicitor was put through a show cause order and a Hamid hearing and referred to the Solicitors Regulation Authority for false citations in grounds drafted by a junior fee-earner and for failing to supervise ([2026] UKUT 81 (IAC), promulgated 17 November 2025). The AI origin of the citations rests on the tribunal's record that he accepted it; his written explanation had named other sources.

Outcome

Pending

The Upper Tribunal referred the solicitor to the Solicitors Regulation Authority in its judgment promulgated on 17 November 2025, stating that it is for the SRA to decide what if any action to take. No SRA outcome has been found. Permission to apply for judicial review had been refused on 20 August 2025 for reasons the judgment does not set out and does not connect to the citations.

What remains unknown

  • Which AI tool generated the false citations, and what was asked of it; the judgment records only the solicitor's acceptance.
  • Whether the junior fee-earner used an AI tool: he did not attend the hearing, and the statements he and the solicitor signed suggested an old precedent as the source of the errors.
  • What action, if any, the Solicitors Regulation Authority has taken on the referral.
  • Whether other files the fee-earner worked on contain false citations; the tribunal said it was likely but unestablished.

What the evidence supports

AI involvement: reported. The judgment records that the solicitor accepted that the junior fee-earner had relied on false citations generated by AI in this case ([52]), and the tribunal referred him to the SRA because the grounds included those false citations and he had failed to supervise their drafting ([56]). The false authorities reached the tribunal in the grounds; the judge identified them, ordered the show cause process and the panel acted on them in deciding to refer the solicitor (informed_decision_about). The AI origin rests on that recorded acceptance and on the tribunal's reference to his failure to put checks in place 'to ensure that the use of AI did not mislead the tribunal' ([46]). Against it, his written explanation had named an outdated precedent, practitioner blogs and personal notes, the statements he and the fee-earner signed suggested an old precedent, which he said he had deleted and could not describe ([53]), at the hearing he said staff had no mechanism to use AI, and the tribunal said the source of the errors does not matter to the referral. No tool or output is identified.

6 claims: 4 documented, 2 reported. What the statuses mean

Documented Judicial review grounds lodged in the Upper Tribunal on 26 June 2025 cited four authorities that the judge could not find or that carried wrong citations, including one citation that does not exist.

Causal attribution. Judge's order of 20 August 2025 as set out in the judgment.

  • caselaw.nationalarchives.gov.uk(opens in new tab) supports · English
    'lodged judicial review proceedings in the Upper Tribunal'; 'What causes me to make that order are the “authorities” cited at [10], [17], [18], and [32] of the grounds.'; 'and no case with the citation [2010] UKUT 35 (IAC) even exists'
Reported The tribunal recorded that the supervising solicitor accepted that the junior fee-earner had relied on false citations generated by AI in this case.

Causal attribution. The tribunal's record of the solicitor's acceptance (the judgment does not say when or in what words he accepted it); no tool, prompt or output is identified.

Reported The solicitor's written explanation of 26 September 2025 said the fee-earner relied on an outdated precedent, practitioner blogs and personal notes, and the tribunal recorded that signed statements by both men suggested the errors might have been caused by an old precedent. At the hearing the solicitor said staff at the firm had no mechanism to use AI, and said he had found and deleted the precedent but could not say what it was.

Causal attribution. The solicitor's and the fee-earner's own accounts as recorded in the judgment; contrary evidence on the AI origin. The solicitor could not identify the precedent ([53]).

  • caselaw.nationalarchives.gov.uk(opens in new tab) supports · English
    'he relied on an outdated precedent on our system, practitioner blogs and personal notes'; 'we were concerned by the suggestion in the statements made by'; 'that the citation errors might have been caused by an “old precedent from previous cases”'; 'He stated that there was no mechanism by which staff at his firm could use AI.'; 'He said that he had, and that he had deleted it.'; 'was unable to offer a clear answer to that question'
Documented The tribunal referred the supervising solicitor to the Solicitors Regulation Authority because the grounds included false citations and he had failed to supervise their drafting, and said it does not matter how such citation errors come about.

Causal attribution. Decision stated in the judgment promulgated on 17 November 2025.

  • caselaw.nationalarchives.gov.uk(opens in new tab) supports · English
    'we consider that the inclusion of false citations in the grounds for judicial review and'; 'necessitates a referral to the SRA'; 'It matters not how such citation errors come about.'
Documented The judgment states that the Upper Tribunal judicial review claim form has been amended to require a legal representative to confirm by a statement of truth that any cited authority exists, can be located with the citation given and supports the proposition for which it is cited.

Causal attribution. Statement in the judgment's headnote and conclusions.

Documented Permission to apply for judicial review was refused on 20 August 2025 for reasons the judgment does not set out.

Causal attribution. Judgment; the refusal is not connected to the citations.

Sources

1 source inspected. Sources that repeat one account do not corroborate each other.

How the sources were read, and where the events happened

Full judgment text read in English by the research agent (an AI) on Find Case Law (HTTP 200); no translation was involved and no human reviewer read it. Applies to s1.

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

Event: the grounds were lodged in the Upper Tribunal (Immigration and Asylum Chamber), the Hamid hearing was held at Field House and the referral is to the Solicitors Regulation Authority (judgment). Court: the Upper Tribunal. The solicitor's residence is not stated.

Reviewed for publication 2026-10-12: Published on the Upper Tribunal's own judgment: false citations in judicial review grounds led the tribunal to refer the supervising solicitor to the SRA, and the tribunal records his acceptance that the junior fee-earner relied on AI-generated citations. The referral is documented; the AI origin is reported and the solicitor's earlier contrary accounts are recorded. The solicitor, the fee-earner and the applicant are private persons and are not named in the public text.

People described

One solicitor, the compliance officer of the firm that lodged the grounds, who was referred to the Solicitors Regulation Authority; named in the judgment but a private practitioner whose regulatory outcome is unknown, not named here.

People reported harmed in this case

1 person

0 AI participants · 1 other person harmed

One person: the supervising solicitor referred to the SRA. He is not counted as an AI user, because the judgment records the junior fee-earner's reliance on AI-generated citations. The fee-earner, who had left the firm and did not attend, and the applicant, whose permission refusal the judgment does not connect to the citations, are not counted.

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

Tags

#ai-hallucination#fabricated-citations#legal#immigration#tribunal#supervision#sra-referral#united-kingdom

Cite this case

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

APA

NOPE. (2026). UK Upper Tribunal refers a supervising solicitor to the SRA over false citations in judicial review grounds; tribunal records he accepted they were AI-generated. AI incidents. https://nope.net/incidents/2025-uk-upper-tribunal-judicial-review-grounds-false-citations-supervising-solicitor-referred-to-sra

BibTeX

@misc{2025_uk_upper_tribunal_judicial_review_grounds_false_citations_supervising_solicitor_referred_to_sra,
  title = {UK Upper Tribunal refers a supervising solicitor to the SRA over false citations in judicial review grounds; tribunal records he accepted they were AI-generated},
  author = {NOPE},
  year = {2026},
  howpublished = {AI incidents},
  url = {https://nope.net/incidents/2025-uk-upper-tribunal-judicial-review-grounds-false-citations-supervising-solicitor-referred-to-sra}
}

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