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HomeCasesAK v Secretary of State for the Home Department
Evidence review: primary document verified. The linked primary document was extracted and checked with page-level evidence locators.
Evidence-linked corpus record: this page is generated from the structured public record and has a publication-readiness score of 95/100. It passes the current publication gate; that is not a legal-editorial review or a guarantee that every field has been independently verified.
Corpus matter record

AK v Secretary of State for the Home Department

Upper Tribunal · Oct 6, 2025

GBEditorial impact: lowfake citationsimmigrationtrialNone Adjudicated
Direct answer

What happened in this matter?

The Upper Tribunal issued a Show Cause Order against a solicitor for including fabricated case law in grounds of appeal, which the judge attributed to the unchecked use of generative AI. The solicitor must explain why his conduct, including the subsequent attempt to conceal the false citations, should not be referred to the Solicitors Regulation Authority.

Why the court cared
The judge reasoned that the inclusion of non-existent authorities constitutes a failure to verify AI-generated drafting, which risks misleading the tribunal. The judge further reasoned that the subsequent removal of these citations from the composite bundle without disclosure suggested a potential attempt to conceal the error, warranting a formal Show Cause Order.
Why it matters now
UK Upper Tribunal sends ChatGPT-drafted grounds straight to the SRA; immigration grounds need partner sign-off on every cite.

Why this matter is tracked

In an appeal before the Upper Tribunal, the appellant's solicitors submitted grounds of appeal containing two non-existent case citations: 'Nye v SSHD [2021] EWCA Civ 148' and 'R (Goudey) v SSHD [2012] EWHC 567 (Admin)'. The presiding judge identified these as fabricated authorities likely generated by unchecked use of ChatGPT. Furthermore, the judge noted that these citations were removed from a subsequent 'composite bundle' without explanation, raising concerns regarding potential dishonesty in attempting to conceal the error. The judge dismissed the underlying appeal on its merits and issued a Show Cause Order requiring the solicitor, Rahat Ullah, to explain why his conduct should not be referred to the Solicitors Regulation Authority (SRA).

Operational lesson

UK Upper Tribunal sends ChatGPT-drafted grounds straight to the SRA; immigration grounds need partner sign-off on every cite.

Record details

CourtUpper Tribunal
Jurisdictioninternational
CircuitNot recorded
DateOct 6, 2025
CH
AI toolChatGPT
Party typeLawyer
OutcomeThe appeal was dismissed, and a Show Cause Order was issued against the solicitor regarding potential referral to the SRA.
Known amountNot recorded
Professional sanctionShow Cause Order issued regarding potential referral to the Solicitors Regulation Authority.
Attribution boundary

What the record establishes about AI use

explicitly recorded

The judge explicitly identified ChatGPT as the source of the fabricated citations.

Procedural posture

The Upper Tribunal dismissed the appellant's appeal on the merits and issued a post-script Show Cause Order directing the solicitor to explain his conduct regarding the submission of fabricated authorities.

Correction behavior

Correction behavior is not separately verified in the current record.

Tracked discrepancy record

2 citation, quotation, or authority issues are recorded in the source dataset.

  1. Fabricated: Case Law | Grounds of appeal cited 'R (Goudey) v SSHD [2012] EWHC 567 (Admin)'; Judge found the authority does not exist and treated it as another example of AI-generated false citation.
  2. Fabricated: Case Law | Grounds of appeal cited 'Nye v SSHD [2021] EWCA Civ 148'; Judge found the authority does not exist and linked it to unchecked generative-AI drafting.

Questions this record answers

What happened in AK v Secretary of State for the Home Department?
The Upper Tribunal issued a Show Cause Order against a solicitor for including fabricated case law in grounds of appeal, which the judge attributed to the unchecked use of generative AI. The solicitor must explain why his conduct, including the subsequent attempt to conceal the false citations, should not be referred to the Solicitors Regulation Authority.
Why does AK v Secretary of State for the Home Department matter for legal AI risk?
UK Upper Tribunal sends ChatGPT-drafted grounds straight to the SRA; immigration grounds need partner sign-off on every cite.
What does the public record establish about AK v Secretary of State for the Home Department?
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Which source supports this AK v Secretary of State for the Home Department summary?
The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.

Related matters

Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.

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