AK v Secretary of State for the Home Department
Upper Tribunal · Oct 6, 2025
- Jurisdiction
- international
- Court
- Upper Tribunal
- Record ID
- ak-v-secretary-of-state-for-the-home-department-2025-10-06
- Observed outcome
- The appeal was dismissed, and a Show Cause Order was issued against the solicitor regarding potential referral to the SRA.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
UK Upper Tribunal sends ChatGPT-drafted grounds straight to the SRA; immigration grounds need partner sign-off on every cite.
Failure modes and consequences
- Fake Citations
- Immigration
- Trial
- None Adjudicated
- AI attribution
- Explicitly Recorded
- Recorded tool
- ChatGPT
- Known monetary consequence
- Not recorded
- 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.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The judge explicitly identified ChatGPT as the source of the fabricated citations.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Implement mandatory verification protocols for all case law citations, regardless of the drafting source.
- Ensure that any amendments to court filings are transparent and clearly disclosed to the tribunal.
- Establish firm-wide policies prohibiting the submission of AI-generated research without human review and verification against primary legal databases.