ANPV & SAPV v Secretary of State for the Home Department
Upper Tribunal · Sep 29, 2025
What happened in this matter?
The Upper Tribunal issued a Show Cause order against counsel for submitting grounds of appeal containing fabricated and misrepresented legal authorities generated via Microsoft Copilot. The judge found that counsel failed to verify the existence or relevance of cited cases and attempted to mislead the tribunal, necessitating a formal explanation regarding potential referral to the Bar Standards Board.
- Why the court cared
- The judge reasoned that the consistent pattern of citing non-existent or irrelevant cases, combined with counsel's inability to locate or explain the authorities, indicated a reliance on generative AI without verification. The judge rejected counsel's suggestion that the AI tool itself misrepresented the cases, noting that the tool provided accurate summaries when tested by the court. The judge determined that the conduct was a serious attempt to mislead the tribunal, warranting a Show Cause order.
- Why it matters now
- Copilot is now generating fake country-guidance authorities; immigration counsel must re-check every CG reference.
Why this matter is tracked
In an appeal before the Upper Tribunal, counsel for the appellants submitted grounds of appeal containing multiple fabricated and misrepresented legal authorities. The presiding judge identified that several cited cases, including a purported Honduras country guidance decision, did not exist. Other cited authorities were either irrelevant to the propositions advanced or misidentified. Counsel admitted to using Microsoft Copilot for research and drafting. The judge concluded that counsel failed to verify the accuracy of the AI-generated content and attempted to mislead the tribunal. Consequently, the judge issued a Show Cause order requiring counsel to explain in writing why his conduct should not be referred to the Bar Standards Board for disciplinary action.
Copilot is now generating fake country-guidance authorities; immigration counsel must re-check every CG reference.
Record details
What the record establishes about AI use
Counsel admitted to using Microsoft Copilot for research.
Upper Tribunal appeal hearing; Show Cause order issued.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
6 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Grounds cited a Honduras country guidance decision that does not exist; judge found the MN Honduras CG [2016] authority fabricated.
- Fabricated: Case Law | Grounds cited an Eritrea appellate decision that does not exist (YH (Eritrea) [2008] UKAIT 00070); judge accepted counsel's concession that case was fictional.
- Misrepresented: Case Law | HK v SSHD [2006] EWCA Civ 1037 was cited as supporting 'trauma-informed principles' but judge found the case does not discuss that; citation misapplied.
- Misrepresented: Case Law | MA (Somalia) v SSHD was referenced but counsel produced the Supreme Court decision instead of the Court of Appeal authority relied upon; judge found no support for the asserted proposition.
- Misrepresented: Case Law | A citation labelled 'SC (Protection) [2020] UKSC 9' did not match the case title; judge found a citation mismatch and irrelevant authority was cited for internal relocation principles.
- Misrepresented: Case Law | R (YH) v SSHD [2010] EWCA Civ 116 was deployed in grounds but judge noted ChatGPT has recently wrongly deployed that case in similar submissions; authority was misused.
Questions this record answers
- What happened in ANPV & SAPV v Secretary of State for the Home Department?
- The Upper Tribunal issued a Show Cause order against counsel for submitting grounds of appeal containing fabricated and misrepresented legal authorities generated via Microsoft Copilot. The judge found that counsel failed to verify the existence or relevance of cited cases and attempted to mislead the tribunal, necessitating a formal explanation regarding potential referral to the Bar Standards Board.
- Why does ANPV & SAPV v Secretary of State for the Home Department matter for legal AI risk?
- Copilot is now generating fake country-guidance authorities; immigration counsel must re-check every CG reference.
- What does the public record establish about ANPV & SAPV 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 ANPV & SAPV 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.