{"meta":{"exportedAt":"2026-10-31T06:30:13.029Z","formatVersion":2,"selection":{"q":"asylum","system":"","harm":"","context":"","country":"","role":"","relation":"","evidence":"","year":"","response":"","severity":"","verification":"","view":"incidents","sort":"added"},"totalIncidents":6,"coverage":{"cases":6,"countries":3,"languages":1,"unknownLocation":0,"locationPending":0,"unknownLanguage":0,"unknownDate":0,"lawsuits":0,"regulatory":3,"minors":0,"coreRelations":3,"contextualRelations":4,"mixedRelations":1,"unknownRelations":0,"relationPending":0,"relationUnknown":0},"countingNote":"Distinct public cases in this selection. People counts apply within individual cases only; cross-case person overlap has not been resolved. No population incidence estimate.","affectedCountNote":"Interpret person counts with affectedCountStatus and the reported effects. Unquantified zeros are placeholders, not a measured zero.","source":"AI incidents","publisher":"NOPE","url":"https://nope.net/incidents","license":"CC BY 4.0"},"incidents":[{"id":"2023-us-mexico-border-cbp-one-asylum-app-face-capture-failed-black-applicants-advocates-say","caseFacts":{"claims":[{"id":"c1","status":"reported","evidence":[{"locator":"The government announced in early January that the new CBP One mobile app would be the only way migrants arriving at the border can apply for asylum and exemption from Title 42 restrictions; which is now required to apply for asylum","relation":"supports","source_id":"s1"},{"locator":"the Biden administration announced in early January that the CBP One app would be the only way people at the border can apply for asylum and an exemption from Title 42.","relation":"supports","source_id":"s2"}],"assertion":"In early January 2023 the US government announced that the CBP One app would be the only way migrants arriving at the US-Mexico border could apply for asylum and exemption from Title 42 restrictions; uploading a photo through the app was required to obtain an appointment.","causal_attribution":"Government announcement as reported; the photo requirement is the reporter's and advocates' description."},{"id":"c2","status":"reported","evidence":[{"locator":"Non-profits that assist Black asylum seekers are finding that the app, CBP One, is failing to register many people with darker skin tones, effectively barring them from their right to request entry into the US.; The facial recognition is not picking up [images] if people have darker skin tones,; held a workshop for Haitians in Tijuana on how to use the app a day after it went live on 12 January. But with the app unable to map the features of many darker-skinned asylum seekers, they cannot upload their photos in order to receive an asylum appointment with the US immigration authorities, Pinheiro said.; The Haitians at the workshop were getting error after error message on the app","relation":"supports","source_id":"s1"},{"locator":"Because the app cannot map the features of darker-skinned asylum seekers, they cannot upload their photo to receive an asylum appointment, Pinheiro said.","relation":"supports","source_id":"s2"}],"assertion":"Non-profits assisting Black asylum seekers said the app's facial recognition was failing to register many people with darker skin tones, so they could not upload their photos to receive asylum appointments; Al Otro Lado's executive director said Haitians at a Tijuana workshop held the day after the app went live on 12 January got error after error message.","causal_attribution":"Advocates' accounts of what they observed; no technical analysis or CBP confirmation is reported."},{"id":"c3","status":"reported","evidence":[{"locator":"There are about 4,000 Black asylum seekers waiting in Reynosa and at least another 1,000 Haitians in Matamoros. Hardly anyone is getting an asylum appointment.","relation":"supports","source_id":"s1"}],"assertion":"The co-director of the Sidewalk School said about 4,000 Black asylum seekers were waiting in Reynosa and at least 1,000 Haitians in Matamoros, and that hardly anyone was getting an asylum appointment.","causal_attribution":"The non-profit's estimate; the figures describe people waiting and are not counted as people harmed."},{"id":"c4","status":"reported","evidence":[{"locator":"One fix they’ve come up with is installing bright construction lights at the shelter in Reynosa, which Haitians and others shine on their faces as they take the photo to upload to the app. “So far it seems to be working, so the adults can get past that,; still not working for children under the age of six.","relation":"supports","source_id":"s1"},{"locator":"This prevents families from being able to apply for asylum, since the app will accept only one or two members of the family, but not the rest.","relation":"supports","source_id":"s2"}],"assertion":"The Sidewalk School said shining bright construction lights on faces let adults get past the photo step, but it still did not work for children under six, which prevented families from applying because the app accepted only some family members.","causal_attribution":"The non-profit's account of its workaround and of families blocked."},{"id":"c5","status":"reported","evidence":[{"locator":"said the CBP One app has helped “lighter-skin toned people from other nations” obtain their asylum appointments “but not Haitians” and other Black applicants.","relation":"supports","source_id":"s1"}],"assertion":"A Haitian Bridge Alliance staff attorney said the app had helped lighter-skinned people from other nations obtain asylum appointments, but not Haitians and other Black applicants.","causal_attribution":"Advocate's comparison; not measured."},{"id":"c6","status":"reported","evidence":[{"locator":"Besides the face recognition technology not registering them, there are other barriers, too. Many asylum seekers have outdated cellphones – if they have cellphones at all – that don’t support the CBP One app and often have limited or no access to the internet.; If you can afford to spend $1,000 on a new cellphone, then you can upload the image no problem.","relation":"supports","source_id":"s1"}],"assertion":"The advocates also described barriers unrelated to facial recognition: many asylum seekers had outdated phones that did not support the app, or limited internet access, and a new phone could upload the image.","causal_attribution":"Kept as context: other causes of failed uploads that the sources do not separate from the face capture."},{"id":"c7","status":"reported","evidence":[{"locator":"CBP did not reply with comments before publication, after being approached with questions by the Guardian.","relation":"supports","source_id":"s1"},{"locator":"The Border Chronicle contacted CBP with several detailed questions about the CBP One app, including the problems with its facial-recognition technology. A spokesperson for CBP, Justin Long, said no one was available to respond.","relation":"supports","source_id":"s2"}],"assertion":"CBP did not reply to the Guardian's questions before publication, and a CBP spokesperson told the Border Chronicle no one was available to respond.","causal_attribution":"The agency's non-response."}],"effects":[{"label":"advocates say darker-skinned asylum seekers could not pass the app's photo step to obtain appointments","claim_id":"c2","direction":"negative"},{"label":"advocates say families with children under six could not apply","claim_id":"c4","direction":"negative"}],"sources":[{"id":"s1","url":"https://www.theguardian.com/us-news/2023/feb/08/us-immigration-cbp-one-app-facial-recognition-bias","kind":"news_report","access":"read","language":"en","translation_note":"Read in English on 2026-10-31; no translation.","independence_group":"del-bosque-cbp-one-2023-02"},{"id":"s2","url":"https://www.theborderchronicle.com/p/facing-bias-cbps-immigration-app","kind":"news_report","access":"read","language":"en","translation_note":"Read in English on 2026-10-31 from an Internet Archive capture of 26 February 2024; no translation. Same reporter as the Guardian article.","independence_group":"del-bosque-cbp-one-2023-02"}],"version":1,"ai_roles":["institutional_use"],"contexts":["public_services","justice"],"unknowns":["How many people the app's face capture rejected; the advocates give no count.","Whether the rejections came from the facial recognition itself, phone cameras or lighting; no technical analysis is reported.","Whether CBP changed the face capture or how long the problem lasted; neither source reports a later response."],"geography":{"basis":"The advocates describe asylum seekers using the app while waiting in the Mexican border cities of Tijuana, Reynosa and Matamoros to request entry into the United States.","court_countries":[],"event_countries":["MX"],"affected_person_countries":["MX"]},"publication":{"basis":"Published as a government asylum app whose facial recognition, according to non-profits that assisted applicants, rejected the photos of many Black asylum seekers so they could not obtain appointments, the only route then available. The account is attributed to the advocates; other barriers and CBP's non-response are recorded.","reviewed_on":"2026-10-31"},"ai_involvement":{"basis":"Non-profits running workshops and shelters for asylum seekers told the Guardian and the Border Chronicle that the CBP One app's facial recognition did not register the faces of many darker-skinned applicants: the app returned error messages and would not accept their photos, which were required to obtain an asylum appointment through the app, the only route CBP allowed at the time. The rejection of the photo is the system's own output and the advocates connect it to applicants being unable to get appointments. The attribution rests on the advocates' observations; no technical analysis is reported, CBP did not respond, and the advocates also cite old phones and poor connectivity.","status":"reported"},"person_relations":["made_decision_about"]},"name":"Advocates say CBP One asylum app's facial recognition rejected photos of Black asylum seekers at the US-Mexico border, blocking appointments","summary":"In January 2023 US Customs and Border Protection (CBP) made its CBP One mobile app the only way for migrants at the US-Mexico border to apply for asylum appointments and exemption from Title 42 restrictions; applicants had to upload a photo of themselves through the app. In February 2023 the Guardian and the Border Chronicle, both reporting by Melissa del Bosque, quoted three non-profits working with Haitian and African asylum seekers in Tijuana, Reynosa and Matamoros who said the app's facial recognition was failing to register many people with darker skin, so they could not upload their photos and obtain appointments. The executive director of Al Otro Lado said Haitians at a workshop her organisation held in Tijuana the day after the app went live got error after error message. The Sidewalk School said hardly anyone among about 4,000 Black asylum seekers in Reynosa and 1,000 Haitians in Matamoros was getting an appointment, and that shining construction lights on faces let adults get past the photo step but not children under six, which kept families from applying. A Haitian Bridge Alliance attorney said the app had helped lighter-skinned applicants but not Haitians. The advocates also described other barriers, such as outdated phones and poor internet access. CBP did not answer the Guardian's questions before publication and told the Border Chronicle no one was available to respond. No technical analysis of the failures is reported.","incidentDate":"2023-01-01","incidentKind":"bounded_series","incidentDatePrecision":"month","exposurePattern":"repeated_interactions","reportedDate":"2023-02-07","aiSystem":"Facial recognition photo capture in US Customs and Border Protection's CBP One mobile app, required in 2023 for migrants at the US-Mexico border to request asylum appointments, as described by non-profits quoted by the Guardian and the Border Chronicle","aiProduct":"CBP One app","severity":"low","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["legal_harm","other_material_harm"],"harmOutcomeSummary":"Advocates say the app's facial recognition failed to register many darker-skinned asylum seekers, so they could not upload their photos or obtain the asylum appointments the app had become the only route to; they say lighting workarounds helped adults but not children under six, which kept families from applying.","frameworkFacets":[],"causationStatus":"alleged","participantUsersAffectedMin":0,"otherPeopleHarmedMin":0,"affectedCountStatus":"unquantified","affectedCountEvidence":"The advocates describe groups (Haitians at a Tijuana workshop, families with young children at a Reynosa shelter) without counts. The figures of about 4,000 Black asylum seekers in Reynosa and 1,000 Haitians in Matamoros describe people waiting, not people whose photos the app rejected, so they are not counted.","victimAgeRange":"unknown","jurisdiction":"US","platformType":"other","outcomeType":"media_coverage","outcomeStatus":"unknown","primarySourceUrl":"https://www.theguardian.com/us-news/2023/feb/08/us-immigration-cbp-one-app-facial-recognition-bias","primarySourceLabel":"The Guardian, Facial recognition bias frustrates Black asylum applicants to US, advocates say, 8 February 2023","firstPublishedAt":"2026-10-31T03:21:06.698324+00:00","updatedAt":"2026-10-31T03:21:06.698324+00:00","scopeVersion":"facts-v3","tags":["cbp-one","facial-recognition","asylum","immigration","public-services","us-mexico-border"]},{"id":"2026-ninth-circuit-immigration-lawyers-suspended-over-ai-hallucinated-citations-board-reciprocal-suspension","caseFacts":{"claims":[{"id":"c1","status":"documented","evidence":[{"locator":"'Sethi filed an opening brief in this case with multiple fabricated citations and quotations'; 'Sethi cited two cases that do not exist and never existed'","relation":"supports","source_id":"s1"}],"assertion":"The opening brief filed for the asylum petitioners and signed by Sethi cited two cases that do not exist and attributed quotations to real opinions that do not contain them.","causal_attribution":"The court's own finding in its order."},{"id":"c2","status":"documented","evidence":[{"locator":"'to which Rounds said that AI “was not used.”'; 'Rounds finally conceded that it was “possible” that AI might have been used by the individual who drafted the briefs'; 'Sethi Law Group employs law school graduates, who are not yet licensed attorneys, to write briefs'; 'that no licensed attorney read the cases cited by the unlicensed brief writer'","relation":"supports","source_id":"s1"}],"assertion":"At oral argument Rounds said AI was not used and later conceded it was possible that the person who drafted the briefs had used AI; the drafter was an unlicensed law graduate whose citations no licensed attorney read.","causal_attribution":"The court's record of the oral argument and of the attorneys' response."},{"id":"c3","status":"documented","evidence":[{"locator":"'that the errors were the product of unauthorized AI use by their Brief Writers and a failure to cite check'","relation":"supports","source_id":"s1"}],"assertion":"Responding to the order to show cause, the attorneys conceded that the errors were probably the product of unauthorised AI use by their brief writers and a failure to check citations.","causal_attribution":"The attorneys' concession as recorded by the court; no AI tool, prompt or output was identified."},{"id":"c4","status":"documented","evidence":[{"locator":"'Neither of them suspected the use of generative AI because the Firm prohibited its use and required the Brief Writers to check all their citations'; 'it is beyond belief that he knew for a fact that it was not used'; 'is owed to this repeated failure of candor'; 'We do not sanction Sethi and Rounds for the simple fact that they or'","relation":"supports","source_id":"s1"}],"assertion":"The attorneys said that at the time of the motion to correct they did not suspect AI because the firm prohibited its use; the court found that Rounds could not have known AI was not used, said it was not sanctioning AI use as such, and attributed the severity of discipline to their repeated failure of candour.","causal_attribution":"The attorneys' explanation and the court's findings, both from the order."},{"id":"c5","status":"documented","evidence":[{"locator":"'Sethi and Rounds are each personally sanctioned in the amount of $2,500'; 'Sethi and Rounds are hereby suspended from practice before this Court for a period of six months starting ten days after this Order is filed'; 'provide a copy of this Order to their clients'; 'serve a copy of this Order on the State Bar of California'","relation":"supports","source_id":"s1"}],"assertion":"The Ninth Circuit fined each attorney $2,500, suspended both from practice before the court for six months, ordered them to give the order to their clients in every pending case, and directed service of the order on the State Bar of California.","causal_attribution":"Established by the court's order."},{"id":"c6","status":"documented","evidence":[{"locator":"'The Board hereby suspends the respondent from practice before the Board of Immigration Appeals, the Immigration Courts, and DHS for 6 months, effective June 13, 2026.'; 'On July 1, 2026, the Board granted the Joint Petition for Immediate Suspension.'; 'previously issued unpublished on September 15, 2026'","relation":"supports","source_id":"s2"}],"assertion":"The Board of Immigration Appeals suspended Sethi from practice before the Board, the immigration courts and DHS for six months, effective 13 June 2026, after granting an immediate suspension on 1 July 2026, and designated the decision as precedent after first issuing it unpublished on 15 September 2026.","causal_attribution":"Established by the Board's decision."},{"id":"c7","status":"documented","evidence":[{"locator":"'the respondent contests the sufficiency of the evidence that he knew that certain errors in his filings were caused by the use of artificial intelligence'; 'the respondent’s claims of hardship to his clients are conclusory'; 'the application of our rules of attorney discipline to misconduct related to the use of AI is not an “outlier penalty,” as the respondent claims'","relation":"supports","source_id":"s2"}],"assertion":"Before the Board, Sethi disputed that he knew AI had been used and argued that suspension would harm his clients and was an outlier penalty for AI-related misconduct; the Board rejected these arguments.","causal_attribution":"The respondent's arguments and the Board's ruling as stated in the decision."},{"id":"c8","status":"documented","evidence":[{"locator":"'The petition for review, which we granted'","relation":"supports","source_id":"s1"}],"assertion":"The court granted the asylum petitioners' petition for review.","causal_attribution":"The court's statement; it does not address any effect of the sanctions on the clients."}],"effects":[{"label":"two attorneys were fined and suspended from practice before a federal appeals court, and one was suspended from immigration practice, over briefs with AI-hallucinated citations and false statements about them","claim_id":"c5","direction":"negative"}],"sources":[{"id":"s1","url":"https://cdn.ca9.uscourts.gov/datastore/opinions/2026/06/03/24-4790.pdf","kind":"court_record","access":"read","language":"en","translation_note":"Read in full in English by the research agent (an AI) on 2026-10-14 from the court's own site (HTTP 200, PDF text extracted with pdftotext); no translation was needed.","independence_group":"ninth-circuit-order-24-4790"},{"id":"s2","url":"https://www.justice.gov/eoir/media/1463666/dl?inline","kind":"court_record","access":"read","language":"en","translation_note":"Read in full in English by the research agent (an AI) on 2026-10-14 from the court's own site (HTTP 200, PDF text extracted with pdftotext); no translation was needed.","independence_group":"bia-matter-of-sethi"}],"version":1,"ai_roles":["others_use"],"contexts":["justice","work"],"unknowns":["Which AI tool the brief writers used; the order records only the attorneys' concession that AI use was probable.","Whether the State Bar of California opened proceedings after the referral.","Whether the suspensions affected the attorneys' clients; the Board found the hardship claims conclusory and no source describes a harmed client.","The date the opening brief was filed; the inspected sources do not state it."],"geography":{"basis":"The briefs were filed in and sanctioned by the US Court of Appeals for the Ninth Circuit, and the reciprocal suspension was imposed by the US Board of Immigration Appeals; the order describes the firm as based in Orange County, California. The attorneys' residence is not used.","court_countries":["US"],"event_countries":["US"],"affected_person_countries":[]},"publication":{"basis":"Published as a court decision about two attorneys informed by AI-generated fabricated authorities in their briefs: the Ninth Circuit's order fines and suspends two attorneys for filing briefs with AI-hallucinated citations and for repeatedly denying the AI source, and the Board of Immigration Appeals imposes a reciprocal suspension on one of them. Both records were read in full from the courts' own sites.","reviewed_on":"2026-10-14"},"ai_involvement":{"basis":"The harm is two courts' response to AI use in filings: the Ninth Circuit order describes briefs with nonexistent cases and misattributed quotations, records the attorneys' concession that the errors were probably the product of unauthorised AI use by the firm's brief writers, and imposes fines and a six-month suspension for filing them and for repeatedly denying the AI source; the Board of Immigration Appeals imposed a reciprocal suspension on that basis. The court read the fabricated authorities in the briefs, identified them and based its discipline of the two attorneys on filing them and on their statements about their source, so the AI output informed a decision about them (informed_decision_about); no tool is named.","status":"supported"},"person_relations":["informed_decision_about"]},"name":"Ninth Circuit fines and suspends two immigration lawyers over briefs with AI-hallucinated citations and denials of AI use; immigration board follows","summary":"On 3 June 2026 the US Court of Appeals for the Ninth Circuit fined immigration attorneys Mike Singh Sethi and William Rounds $2,500 each and suspended both from practice before the court for six months. Briefs filed in an asylum petition for review cited two cases that do not exist and attributed quotations to opinions that do not contain them. In a motion to correct, the attorneys called the errors typographical, and at oral argument Rounds twice said AI was not used. In their response to the court's order to show cause, they conceded that the errors were probably the product of unauthorised AI use by the firm's unlicensed brief writers and a failure to check citations. The court said the suspension was owed to their repeated failure of candour. The Board of Immigration Appeals then suspended Sethi from practice before the Board, the immigration courts and the Department of Homeland Security for six months, effective 13 June 2026, and designated that decision as a precedent on 1 October 2026.","incidentDate":"2026-06-03","incidentKind":"single_event","incidentDatePrecision":"day","exposurePattern":"unknown","reportedDate":"2026-06-03","aiSystem":"Generative AI that, according to the attorneys' concession recorded by the Ninth Circuit, the firm's unlicensed brief writers probably used against firm policy; no tool is named in the order or the Board's decision","aiProduct":"Unidentified AI tool","severity":"medium","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["professional_harm","financial_loss","legal_harm"],"harmOutcomeSummary":"According to the Ninth Circuit's order, both attorneys were fined $2,500 and suspended from practice before the court for six months over briefs whose AI-hallucinated citations they had denied were AI errors; according to the Board of Immigration Appeals, one of them was then suspended from practice before the immigration courts, the Board and DHS for six months.","frameworkFacets":[],"causationStatus":"established","participantUsersAffectedMin":0,"otherPeopleHarmedMin":2,"affectedCountStatus":"exact","affectedCountEvidence":"Two attorneys, each named in the Ninth Circuit order as fined and suspended; the Board's reciprocal suspension concerns one of them. The asylum applicants are not counted: the court granted their petition for review and no source reports harm to them.","victimAgeRange":"adult","jurisdiction":"US","platformType":"other","outcomeType":"regulatory_action","outcomeStatus":"resolved","primarySourceUrl":"https://cdn.ca9.uscourts.gov/datastore/opinions/2026/06/03/24-4790.pdf","primarySourceLabel":"US Court of Appeals for the Ninth Circuit, order in No. 24-4790 (3 June 2026): attorney discipline over AI-hallucinated citations","firstPublishedAt":"2026-10-14T03:02:36.457192+00:00","updatedAt":"2026-10-14T03:02:36.457192+00:00","scopeVersion":"facts-v3","tags":["united-states","legal-profession","sanction","suspension","hallucinated-citations","immigration"]},{"id":"2025-uk-upper-tribunal-judicial-review-grounds-false-citations-supervising-solicitor-referred-to-sra","caseFacts":{"claims":[{"id":"c1","status":"documented","evidence":[{"locator":"'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'","relation":"supports","source_id":"s1"}],"assertion":"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."},{"id":"c2","status":"reported","evidence":[{"locator":"'may have relied on false citations which were generated by AI, as'; 'accepted he had done in this case'","relation":"supports","source_id":"s1"}],"assertion":"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."},{"id":"c3","status":"reported","evidence":[{"locator":"'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'","relation":"supports","source_id":"s1"}],"assertion":"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])."},{"id":"c4","status":"documented","evidence":[{"locator":"'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.'","relation":"supports","source_id":"s1"}],"assertion":"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."},{"id":"c5","status":"documented","evidence":[{"locator":"'has now been amended so as to require a legal representative to confirm by a statement of truth that any authority cited within the form'","relation":"supports","source_id":"s1"}],"assertion":"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."},{"id":"c6","status":"documented","evidence":[{"locator":"'He refused permission for reasons which we need not set out.'","relation":"supports","source_id":"s1"}],"assertion":"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."}],"effects":[{"label":"supervising solicitor referred to the SRA over false citations in judicial review grounds drafted by a junior fee-earner","claim_id":"c4","direction":"negative"}],"sources":[{"id":"s1","url":"https://caselaw.nationalarchives.gov.uk/ukut/iac/2026/81","kind":"court_record","access":"read","language":"en","translation_note":"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.","independence_group":"ukut-2026-81-judgment"}],"version":1,"ai_roles":["others_use"],"contexts":["justice","work"],"unknowns":["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."],"geography":{"basis":"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.","court_countries":["GB"],"event_countries":["GB"],"affected_person_countries":[]},"publication":{"basis":"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.","reviewed_on":"2026-10-12"},"ai_involvement":{"basis":"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.","status":"reported"},"person_relations":["informed_decision_about"]},"name":"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","summary":"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.","incidentDate":"2025-06-26","incidentEndDate":"2025-11-17","incidentKind":"single_event","incidentDatePrecision":"day","exposurePattern":"unknown","reportedDate":"2025-11-17","aiSystem":"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","aiProduct":"Unidentified AI tool","severity":"medium","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["professional_harm"],"harmOutcomeSummary":"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.","frameworkFacets":[],"causationStatus":"supported","participantUsersAffectedMin":0,"otherPeopleHarmedMin":1,"affectedCountStatus":"exact","affectedCountEvidence":"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.","victimAgeRange":"adult","jurisdiction":"GB","platformType":"other","outcomeType":"regulatory_action","outcomeStatus":"pending","primarySourceUrl":"https://caselaw.nationalarchives.gov.uk/ukut/iac/2026/81","primarySourceLabel":"Find Case Law, [2026] UKUT 81 (IAC), UK v SSHD (AI hallucinations; supervision; Hamid), promulgated 17 November 2025","firstPublishedAt":"2026-10-12T03:12:31.6959+00:00","updatedAt":"2026-10-12T03:12:31.6959+00:00","scopeVersion":"facts-v3","tags":["ai-hallucination","fabricated-citations","legal","immigration","tribunal","supervision","sra-referral","united-kingdom"]},{"id":"2025-uk-upper-tribunal-immigration-adviser-google-ai-mode-fake-case-in-appeal-grounds-regulator-self-report","caseFacts":{"claims":[{"id":"c1","status":"documented","evidence":[{"locator":"'he was the person responsible for the case and drafting of the grounds of 17th March 2025 in this matter.'; 'provide an explanation for the fact that the case Horleston v SSHD [2007] EWCA Civ 654 cited in the grounds of appeal to the Upper Tribunal is not available on BAILII'","relation":"supports","source_id":"s1"}],"assertion":"Grounds of appeal dated 17 March 2025, drafted by the adviser, cited a case (Horleston v SSHD [2007] EWCA Civ 654) that the Upper Tribunal could not find, under the citation of an unrelated case; the tribunal issued a show cause notice.","causal_attribution":"Established by the judgment's own record of the show cause notice and the adviser's response."},{"id":"c2","status":"reported","evidence":[{"locator":"'We confirm unequivocally that no AI large language model (such as ChatGPT) was used in drafting the grounds of appeal.'; 'In absence of an explanation and with how AI operates, I cannot dismiss the fact that the case was an AI creation as there is no other explanation.'; 'his best guess was that he had inadvertently used the “AI Mode” of a Google search by clicking on this on the bar under the search topic.'; 'concluded himself that it was probable that this had happened because of the inadvertent use of an AI large language model'; 'As far as the Panel could establish there had never been a reported case called Horleston but Google AI nevertheless can, depending on the question posed, produce information such as panels of Court of Appeal judges who sat on this non-existent case'; 'By asking Google AI the same question in slightly different ways, we were able to elicit various different compositions of the bench which decided that fictitious case.'","relation":"supports","source_id":"s1"}],"assertion":"The adviser first denied using an AI large language model, later said he could not dismiss that the case was an AI creation, and at the hearing gave as his best guess that he had inadvertently used Google's 'AI Mode'; the tribunal found he had concluded it was probable the fake case came from inadvertent AI use, and the panel elicited varying benches for the fictitious case from Google AI.","causal_attribution":"The tribunal documents what the adviser said and its own test of Google AI; the source of the case in the drafting rests on his conclusion and best guess, so the claim is reported."},{"id":"c3","status":"documented","evidence":[{"locator":"'reported himself to the IAA and to the SRA for having unknowingly inserted a non-existent case in grounds of appeal'; 'has already done this and there is no need for us to do so. If he had not done this we wish to make it clear that we would have made a referral'","relation":"supports","source_id":"s1"}],"assertion":"The adviser reported himself to the IAA and the SRA for having unknowingly inserted a non-existent case, and the tribunal made no referral for that reason, stating it would otherwise have referred him.","causal_attribution":"Established by the judgment's findings and its stated decision on referral."},{"id":"c4","status":"reported","evidence":[{"locator":"'he had put client emails he had drafted explaining Home Office decisions into ChatGPT to try to improve them and he had uploaded Home Office decision letters to this platform to summarise them for clients.'; 'He informed us that he now realises that this is a data breach and will inform the clients that he has done this, as well as the IAA and the SRA.'; 'to put client letters and decision letters from the Home Office into an open source AI tool, such as ChatGPT, is to place this information on the internet in the public domain, and thus to breach client confidentiality and waive legal privilege'","relation":"supports","source_id":"s1"}],"assertion":"The adviser told the tribunal he had put client emails explaining Home Office decisions into ChatGPT and uploaded Home Office decision letters to it to summarise them, called this a data breach he would disclose to the clients, the IAA and the SRA; the tribunal said such uploads breach client confidentiality and waive legal privilege.","causal_attribution":"The uploads rest on the adviser's own account as recorded by the tribunal; the tribunal's statement on confidentiality is its own observation. The clients' number and whether they were told are not stated."}],"effects":[{"label":"non-existent case, probably from Google AI Mode by his own account, placed in appeal grounds he drafted","claim_id":"c2","direction":"negative"},{"label":"self-reported to the IAA and the SRA; the tribunal would otherwise have referred him","claim_id":"c3","direction":"negative"}],"sources":[{"id":"s1","url":"https://caselaw.nationalarchives.gov.uk/ukut/iac/2026/81","kind":"court_record","access":"read","language":"en","translation_note":"Full judgment text read on Find Case Law (HTTP 200); no translation.","independence_group":"ukut-2026-81-judgment"}],"version":1,"ai_roles":["own_use"],"contexts":["justice","work"],"unknowns":["Whether the false case actually came from Google AI Mode; the judgment records the adviser's best guess and conclusion, with no search history or output","What effect, if any, the false case had on the appellant's permission application","How many clients' emails or decision letters were put into ChatGPT and whether they were informed","The outcome of the IAA and SRA self-reports"],"geography":{"basis":"Event: the grounds were filed with the First-tier and Upper Tribunal (Immigration and Asylum Chamber), heard at Field House, and the adviser practises under the UK regulators IAA and SRA (judgment). Court: the Upper Tribunal. The adviser's and clients' countries of residence are not stated.","court_countries":["GB"],"event_countries":["GB"],"affected_person_countries":[]},"publication":{"basis":"Published from the full Upper Tribunal judgment: it documents the false case in grounds the adviser drafted and his self-reports to two regulators, and records his conclusion that the case probably came from inadvertent AI use and his best guess that the tool was Google AI Mode, which the panel's own Google AI test illustrates. The AI source is attributed to his account; his separate account of uploading client documents to ChatGPT is context. The adviser is described by role; the anonymised appellant is not counted.","reviewed_on":"2026-10-11"},"ai_involvement":{"basis":"The judgment records the adviser's best guess that the non-existent case came from his inadvertent use of Google's 'AI Mode', and finds that he concluded it was probable the case was included because of inadvertent use of an AI large language model; the panel reproduced Google AI generating different benches for the same fictitious case. The output reached him through his own search (communicated_with) and went into the grounds that led to the show cause notice and his self-reports. This rests on his account as recorded by the tribunal; he first denied AI use. His separate account of putting client emails and Home Office decision letters into ChatGPT is described as context and is not part of this case's harm.","status":"reported"},"person_relations":["communicated_with"]},"name":"UK Upper Tribunal: immigration adviser gives Google AI Mode as his best guess for a non-existent case in grounds he drafted; he self-reported to regulators","summary":"In the first of two matters decided together in [2026] UKUT 81 (IAC), promulgated on 17 November 2025, the Upper Tribunal (Immigration and Asylum Chamber) examined grounds of appeal dated 17 March 2025 that cited a non-existent Court of Appeal case under the citation of an unrelated equal-pay case. The adviser who drafted them first denied using AI, then told the tribunal his best guess was that he had inadvertently used Google's 'AI Mode', and the tribunal recorded that he had concluded it was probable the case came from inadvertent AI use; the panel itself got Google AI to produce varying benches for the fictitious case. He reported himself to the Immigration Advice Authority and the Solicitors Regulation Authority, and the tribunal said it would otherwise have referred him. He also told the tribunal that he had put client emails and uploaded Home Office decision letters into ChatGPT to summarise them, which he called a data breach he would disclose to the clients; the tribunal said such uploads breach client confidentiality and waive privilege.","incidentDate":"2025-03-17","incidentKind":"single_event","incidentDatePrecision":"day","exposurePattern":"unknown","reportedDate":"2025-11-17","aiSystem":"Google search 'AI Mode', identified by the adviser as his best guess for the source of the false case","aiProduct":"Google AI Mode (reported)","severity":"low","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["professional_harm"],"harmOutcomeSummary":"According to the Upper Tribunal's judgment, an immigration adviser placed a non-existent case in appeal grounds, which the tribunal found he had concluded probably came from inadvertent AI use (his best guess: Google AI Mode); he self-reported to the IAA and the SRA, and the tribunal said it would otherwise have referred him.","frameworkFacets":[],"causationStatus":"supported","participantUsersAffectedMin":1,"otherPeopleHarmedMin":0,"affectedCountStatus":"exact","affectedCountEvidence":"One counted person: the adviser, who used the AI and faced the regulatory consequence. His clients whose emails and decision letters he said he put into ChatGPT belong to a separate, undated matter described as context and are not counted. The appellant in the matter is not counted because no consequence of the false case for the appeal is stated.","victimAgeRange":"adult","jurisdiction":"GB","platformType":"other","outcomeType":"internal_action","outcomeStatus":"ongoing","primarySourceUrl":"https://caselaw.nationalarchives.gov.uk/ukut/iac/2026/81","primarySourceLabel":"Find Case Law, [2026] UKUT 81 (IAC), UK v SSHD (AI hallucinations; supervision; Hamid), promulgated 17 November 2025","firstPublishedAt":"2026-10-11T03:13:21.379148+00:00","updatedAt":"2026-10-11T07:27:35.689369+00:00","scopeVersion":"facts-v3","tags":["ai-hallucination","fabricated-citations","legal","immigration","tribunal","google-ai-mode","united-kingdom","communicated-with"]},{"id":"2025-uk-upper-tribunal-asylum-appeal-chatgpt-grounds-fake-cases-invented-quotes-sra-self-report","caseFacts":{"claims":[{"id":"c1","status":"documented","evidence":[{"locator":"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.","relation":"supports","source_id":"s1"},{"locator":"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.","relation":"supports","source_id":"s1"},{"locator":"In this case, Mr Badar identified at least 18 separate errors in the grounds of appeal and withdrew three of the four grounds.","relation":"supports","source_id":"s1"}],"assertion":"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."},{"id":"c2","status":"documented","evidence":[{"locator":"Both were produced by a junior member of staff, namely a paralegal, using ChatGPT, which itself raises significant concerns about client confidentiality and legal privilege.","relation":"supports","source_id":"s1"},{"locator":"This occurred because Sarker Solicitors did not check the accuracy of the grounds of appeal, did not consider the grant of permission and did not check the accuracy of the skeleton argument.","relation":"supports","source_id":"s1"},{"locator":"They accepted that AI was used to generate the grounds of appeal filed in the FtT and the skeleton argument filed in the UT.","relation":"supports","source_id":"s1"},{"locator":"The grounds of appeal and skeleton argument were drafted by an unnamed paralegal working for east London firm Sarker Solicitors.","relation":"supports","source_id":"s2"}],"assertion":"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)."},{"id":"c3","status":"documented","evidence":[{"locator":"A hearing was listed before Deputy Upper Tribunal Judge Hobbs on 17 September 2025 to consider whether Judge Balroop had erred in law.","relation":"supports","source_id":"s1"},{"locator":"Judge Hobbs adjourned the hearing, with directions which included the following:","relation":"supports","source_id":"s1"},{"locator":"We note that issues (2) to (4), which occupied a great deal of time at the hearing before us, only arose because of Sarker Solicitors’ inappropriate use of AI.","relation":"supports","source_id":"s1"},{"locator":"The appellant withdrew the original grounds (1), (2) and (4).","relation":"supports","source_id":"s1"},{"locator":"The appellant’s application for permission to amend ground (3) is granted.","relation":"supports","source_id":"s1"},{"locator":"We accept Mr Terrell’s submission that it is not in the interests of justice in this case that the appellant be permitted to advance entirely new grounds, or to replace grounds riddled with misrepresentations, well beyond the original time limit for seeking permission to appeal.","relation":"supports","source_id":"s1"},{"locator":"We therefore refuse the application for permission to amend in respect of the new grounds (4) and (5).","relation":"supports","source_id":"s1"},{"locator":"The appellant’s application for permission to amend grounds (4) and (5) is refused. For completeness, grounds (4) and (5) have been considered in the alternative and disclose no error of law.","relation":"supports","source_id":"s1"},{"locator":"However, ground (3) discloses no error of law.","relation":"supports","source_id":"s1"},{"locator":"The appellant’s appeal therefore fails.","relation":"supports","source_id":"s1"},{"locator":"The judge declined to set aside permission to appeal but dismissed the appeal in any case. The Home Office was invited to file and serve any wasted costs application on Sarker Solicitors within 28 days.","relation":"supports","source_id":"s2"}],"assertion":"The error-of-law hearing listed for 17 September 2025 was adjourned, and 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. The tribunal allowed an amended version of her surviving ground (3) but found that it disclosed no error of law. It refused permission to add new grounds (4) and (5), holding that it was not in the interests of justice to let her advance entirely new grounds, or replace grounds riddled with misrepresentations, well beyond the original time limit, and in the alternative found those grounds without merit. Her appeal failed.","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. It gives the misrepresentation-riddled original grounds and the late application as its reasons for refusing the new grounds (para 65), and it also found those grounds without merit in the alternative (para 74). It states separately that the surviving ground failed on its merits, so the dismissal itself is not attributed to the AI output."},{"id":"c4","status":"documented","evidence":[{"locator":"Two individuals have reported themselves to the Solicitors Regulation Authority and so we will say nothing about the professional conduct issues involved.","relation":"supports","source_id":"s1"},{"locator":"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.","relation":"supports","source_id":"s1"},{"locator":"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.","relation":"supports","source_id":"s2"}],"assertion":"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."},{"id":"c5","status":"documented","evidence":[{"locator":"It would be misleading to describe them as having been caused by AI, rather than by the solicitors’ misuse of AI.","relation":"supports","source_id":"s1"},{"locator":"This was one of the more extreme examples of the misuse of AI, rather than a mere mis-citation of particular cases.","relation":"supports","source_id":"s1"}],"assertion":"The tribunal said it would be misleading to describe the irregularities as caused by AI rather than by the solicitors' misuse of AI. It recorded the Home Office's submission that this was 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. The Home Office's characterisations (at best negligent, at worst reckless, and one of the more extreme examples of the misuse of AI) are relayed in the decision as its submissions (para 43)."}],"effects":[{"label":"Appellant's protection appeal pursued on AI-generated grounds containing fake cases and invented quotations; hearing adjourned and three of four grounds withdrawn","claim_id":"c3","direction":"negative"},{"label":"Two individuals self-reported to the Solicitors Regulation Authority; wasted costs application against the firm invited","claim_id":"c4","direction":"negative"}],"sources":[{"id":"s1","url":"https://tribunalsdecisions.service.gov.uk/utiac/ui-2025-002601","kind":"court_record","access":"read","language":"en","translation_note":"","independence_group":"ut-decision-ui-2025-002601"},{"id":"s2","url":"https://www.lawgazette.co.uk/news/duo-self-report-to-sra-over-grounds-of-appeal-infected-with-ai/5128148.article","kind":"news_report","access":"read","language":"en","translation_note":"","independence_group":"ut-decision-ui-2025-002601"}],"version":1,"ai_roles":["others_use"],"contexts":["justice"],"unknowns":["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 that her surviving, amended ground disclosed no error of law, and that the two new grounds it refused to admit disclosed none either when considered in the alternative."],"geography":{"basis":"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.","court_countries":["GB"],"event_countries":["GB"],"affected_person_countries":["GB"]},"publication":{"basis":"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, and the decision was re-read on 2026-10-11 for this correction. 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 refusal of permission to add new 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.","reviewed_on":"2026-10-11"},"ai_involvement":{"basis":"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 (paras 46-47, 65 and 74). 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.","status":"supported"},"person_relations":["acted_on_behalf","informed_decision_about"]},"name":"UK Upper Tribunal: solicitors' ChatGPT-drafted grounds in an asylum appeal cited fake cases and invented quotes; two individuals self-report to the SRA","summary":"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, and the appellant later withdrew three of her four original grounds. The tribunal allowed an amended version of her one surviving ground but found that it disclosed no error of law. It refused her permission to add two new grounds, holding that she should not be allowed to advance entirely new grounds, or replace grounds riddled with misrepresentations, so long after the time limit, and in the alternative found those grounds without merit. It 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.","incidentDate":"2025-09-17","incidentEndDate":"2026-09-21","incidentKind":"bounded_series","incidentDatePrecision":"range","exposurePattern":"unknown","reportedDate":"2026-10-06","aiSystem":"ChatGPT, used by a paralegal to generate grounds of appeal and a skeleton argument (as found in the Upper Tribunal decision)","aiProduct":"ChatGPT","aiCompany":"OpenAI","severity":"low","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["legal_harm","professional_harm"],"harmOutcomeSummary":"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, that it refused her permission to add two new grounds, holding that she should not be allowed to advance entirely new grounds, or replace grounds riddled with misrepresentations, long after the time limit, and that her appeal fails. It found her one surviving, amended ground disclosed no error of law and, in the alternative, that the two refused grounds disclosed none either. 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.","frameworkFacets":[],"causationStatus":"established","participantUsersAffectedMin":0,"otherPeopleHarmedMin":1,"affectedCountStatus":"documented_minimum","affectedCountEvidence":"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.","victimAgeRange":"adult","jurisdiction":"GB","platformType":"chatbot","primarySourceUrl":"https://tribunalsdecisions.service.gov.uk/utiac/ui-2025-002601","primarySourceLabel":"Upper Tribunal (Immigration and Asylum Chamber), UI-2025-002601, decision issued 21 September 2026, published 6 October 2026","firstPublishedAt":"2026-10-09T03:28:56.311373+00:00","updatedAt":"2026-10-11T07:43:28.275795+00:00","scopeVersion":"facts-v3","tags":[]},{"id":"2026-kumar-sdt-strike-off-ai-citations","caseFacts":{"claims":[{"id":"c1","status":"documented","evidence":[{"locator":"SDT judgment, Allegation 2.1 findings and the schedule of false/miscited authorities.","relation":"supports","source_id":"s1"},{"locator":"RollOnFriday's listing of the bogus citations.","relation":"context","source_id":"s4"}],"assertion":"Allegation 2.1 was found proved: Kumar's 12 March 2026 Answer to the SRA's Rule 12 Statement contained misleading quotations and citations produced with generative AI, including the non-existent 'SRA v Chan [2020] EWHC 1502', the miscited 'SRA v James, MacGregor & Naylor [2018] EWCA Civ 1420' (in reality an IP case) and a misattributed Baxendale-Walker passage.","causal_attribution":"Directly established by the tribunal's written judgment; trade press accounts are consistent."},{"id":"c2","status":"documented","evidence":[{"locator":"SDT judgment, Allegation 2.2 findings and the 13 April acceptance.","relation":"supports","source_id":"s1"}],"assertion":"Allegation 2.2 was found proved: his 9 April 2026 email admitting AI use was itself AI-drafted and contained further errors, which he accepted on 13 April 2026.","causal_attribution":"Directly established by the tribunal's written judgment."},{"id":"c3","status":"documented","evidence":[{"locator":"SDT judgment, sanction and reasoning passages.","relation":"supports","source_id":"s1"},{"locator":"Outer Temple's case note confirming the outcome and the 'first SDT case on a lawyer's use of AI' framing.","relation":"context","source_id":"s5"}],"assertion":"On 25 August 2026 the SDT struck Kumar off the Register of Foreign Lawyers with culpability 'very high', stating it would have struck him off on either allegation alone; the tribunal invoked Ayinde v Haringey LBC [2025] EWHC 1383 (Admin).","causal_attribution":"Directly established by the tribunal's written judgment; the 'first AI case' framing comes from the SRA's counsel and is attributed."},{"id":"c4","status":"documented","evidence":[{"locator":"SDT judgment, conviction allegation and sentence passages.","relation":"supports","source_id":"s1"},{"locator":"RollOnFriday's Isleworth Crown Court reference (recorded as a discrepancy; the judgment controls).","relation":"contradicts","source_id":"s4"}],"assertion":"The parallel ground was his 29 January 2024 conviction under s.21 of the Immigration, Asylum and Nationality Act 2006 — recorded by the judgment as at the Central Criminal Court (RollOnFriday says Isleworth Crown Court, a discrepancy) — sentenced on 26 April 2024 to a 12-month community order with 150 hours' unpaid work.","causal_attribution":"The conviction ground is established by the judgment; the convicting-court discrepancy across outlets is preserved."}],"effects":[{"label":"lawyer struck off after AI-generated false citations in his disciplinary defence","claim_id":"c3","direction":"negative"}],"sources":[{"id":"s1","url":"https://solicitorstribunal.org.uk/wp-content/uploads/2026/03/12884-2026-Kumar-.pdf","kind":"tribunal_judgment","access":"read","language":"en","translation_note":"Judgment PDF read on 2026-09-15 (25 Aug 2026): allegations, findings, sanction, panel, and the Ayinde v Haringey invocation.","independence_group":"sdt"},{"id":"s2","url":"https://www.legalfutures.co.uk/latest-news/lawyer-struck-off-for-using-fake-ai-generated-cases-before-sdt","kind":"trade_press","access":"read","language":"en","translation_note":"Read in English on 2026-09-15 (4 Sep 2026).","independence_group":"legal-futures"},{"id":"s3","url":"https://www.lawgazette.co.uk/news/foreign-lawyer-produced-ai-generated-false-citations-at-sdt/5127825.article","kind":"trade_press","access":"read","language":"en","translation_note":"Read in English on 2026-09-15 (4 Sep 2026, Hyde).","independence_group":"law-gazette"},{"id":"s4","url":"https://www.rollonfriday.com/news-content/first-lawyer-struck-ai-addiction","kind":"trade_press","access":"read","language":"en","translation_note":"Read in English on 2026-09-15 (11 Sep 2026). Colour and the specific bogus citations; its 'AI addiction' framing is editorial joking, not a finding.","independence_group":"rollonfriday"},{"id":"s5","url":"https://www.outertemple.com/joshua-hitchens-acts-for-the-sra-in-the-first-solicitors-disciplinary-tribunal-case-on-a-lawyers-use-of-ai/","kind":"counsel_case_note","access":"read","language":"en","translation_note":"Read in English on 2026-09-15 (8 Sep 2026). SRA counsel's chambers' note: case number, dates, judgment link, and the 'first SDT case on a lawyer's use of AI' framing; participant-side account, recorded as such.","independence_group":"outer-temple"}],"version":1,"ai_roles":["own_use"],"contexts":["work","justice"],"unknowns":["The specific generative AI tool is not named in the inspected accounts.","The convicting court appears as the Central Criminal Court in the judgment and Isleworth Crown Court in RollOnFriday; the judgment controls but the discrepancy is unresolved in the inspected material.","Whether Kumar seeks to appeal the strike-off is not reported.","His employment status after the strike-off is not reported; the Law Gazette's employment background predates it."],"geography":{"basis":"Events: his practice and the SRA proceedings in England. Affected person: Kumar, on the Register of Foreign Lawyers in England and Wales. Court: the Solicitors Disciplinary Tribunal; the parallel conviction was at the Central Criminal Court (per the judgment; RollOnFriday's Isleworth Crown Court is a recorded discrepancy).","court_countries":["GB"],"event_countries":["GB"],"affected_person_countries":["GB"]},"publication":{"basis":"Published under the 2026-09-15 charter as an own-use, work-context adverse consequence with tribunal-found AI misconduct and a dated, career-ending sanction. This applies the charter's individual-review rule to the AI-sanction class; a class-level ruling is not required. Kumar is named in a public tribunal judgment; the parallel conviction ground is recorded for completeness and is not used to inflate the AI link. RollOnFriday's 'AI addiction' framing is recorded as editorial joking.","reviewed_on":"2026-09-15"},"ai_involvement":{"basis":"Tribunal-found: the 12 March 2026 Answer's misleading quotations and citations were produced with generative AI, and the 9 April 2026 email admitting AI use was itself AI-drafted with further errors (accepted 13 April). The specific tool is not named in the inspected accounts.","status":"supported"},"person_relations":["communicated_with"]},"name":"SDT strikes solicitor Abhishek Kumar off the Register of Foreign Lawyers after AI-generated false citations in his SRA defence","summary":"On 25 August 2026 the Solicitors Disciplinary Tribunal struck Abhishek Kumar off the Register of Foreign Lawyers after finding proved that his 12 March 2026 Answer to the SRA's Rule 12 Statement contained misleading quotations and citations produced with generative AI — including a non-existent 'SRA v Chan [2020] EWHC 1502' and a miscited 'SRA v James, MacGregor & Naylor [2018] EWCA Civ 1420' that is actually an intellectual-property case — and that his 9 April 2026 email admitting AI use was itself AI-drafted with further errors. The tribunal said it would have struck him off on that allegation alone; the parallel ground was his January 2024 conviction under s.21 of the Immigration, Asylum and Nationality Act 2006. This is the SDT's first case on a lawyer's use of AI, per the SRA's counsel.","incidentDate":"2026-03-12","incidentEndDate":"2026-08-25","incidentKind":"bounded_series","incidentDatePrecision":"range","exposurePattern":"repeated_interactions","reportedDate":"2026-09-04","aiSystem":"Generative AI (tool not named in inspected accounts)","aiProduct":"Unidentified AI tool","aiCompany":"Unknown","severity":"high","verificationStatus":"verified","harmCategories":[],"harmOutcomes":["professional_harm","legal_harm"],"harmOutcomeSummary":"Career-ending professional consequence for the lawyer who submitted AI-generated false citations in his own disciplinary defence: struck off the Register of Foreign Lawyers on 25 August 2026, with culpability rated 'very high'.","frameworkFacets":[],"causationStatus":"established","participantUsersAffectedMin":1,"otherPeopleHarmedMin":0,"affectedCountStatus":"exact","affectedCountEvidence":"One documented harmed person: Kumar himself, the AI user struck off (SDT judgment). No client or third-party harm is reported in the inspected sources and none is counted.","victimAgeRange":"adult","jurisdiction":"GB","platformType":"other","outcomeType":"regulatory_action","outcomeStatus":"resolved","primarySourceUrl":"https://solicitorstribunal.org.uk/wp-content/uploads/2026/03/12884-2026-Kumar-.pdf","primarySourceLabel":"Solicitors Disciplinary Tribunal judgment, SRA Ltd v Abhishek Kumar, Case No. 12884-2026 (25 Aug 2026)","firstPublishedAt":"2026-09-15T06:18:05.203137+00:00","updatedAt":"2026-09-30T01:17:43.433309+00:00","scopeVersion":"facts-v3","tags":["work","justice","legal-profession","strike-off","fabricated-citations","sdt","own-use","uk"]}]}