{"meta":{"exportedAt":"2026-10-11T08:49:06.844Z","formatVersion":2,"selection":{"q":"tribunal","system":"","harm":"","context":"","country":"","role":"","relation":"","evidence":"","year":"2025","response":"","severity":"","verification":"","view":"incidents","sort":"added"},"totalIncidents":2,"coverage":{"cases":2,"countries":1,"languages":1,"unknownLocation":0,"locationPending":0,"unknownLanguage":0,"unknownDate":0,"lawsuits":0,"regulatory":0,"minors":0,"coreRelations":2,"contextualRelations":1,"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":"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":[]}]}