{"meta":{"exportedAt":"2026-10-23T07:23:34.705Z","formatVersion":2,"selection":{"q":"uk","system":"","harm":"","context":"","country":"","role":"","relation":"contextual","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":1,"minors":0,"coreRelations":1,"contextualRelations":2,"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-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it); no tool, prompt or output is identified."},{"id":"c3","status":"reported","evidence":[{"locator":"'he relied on an outdated precedent on our system, practitioner blogs and personal notes'; 'we were concerned by the suggestion in the statements made by'; 'that the citation errors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-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":[]}]}