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Corpus matter record

MS (Bangladesh)

Immigration and Asylum Chamber · Aug 12, 2025

GBEditorial impact: highfake citationsimmigrationtrialBar ReferralProfessional
Direct answer

What happened in this matter?

The Upper Tribunal referred counsel to the Bar Standards Board (BSB) for investigation after he repeatedly relied on ChatGPT to generate and defend a fabricated legal authority ('Y (China)') in immigration proceedings, failing to perform mandatory verification checks and attempting to mislead the Tribunal regarding the source of his research.

Why the court cared
The Tribunal reasoned that counsel breached professional duties by failing to verify citations using reputable sources (e.g., Bailii, Westlaw). The decision to refer to the BSB was based on the finding that counsel attempted to mislead the Tribunal, lacked honesty in his initial explanations, and failed to meet the standard of work required of a barrister, thereby wasting public resources.
Why it matters now
Handing the Panel ChatGPT-fabricated 'Y (China)' printouts triggered BSB referral — ban consumer AI from appellate immigration bundles.

Why this matter is tracked

In MS (Bangladesh) [2025] UKUT 00305 (IAC), the Upper Tribunal addressed the conduct of counsel, Mr. Muhammad Mujeebur Rahman, who relied on ChatGPT to generate legal research. Counsel cited a non-existent Court of Appeal authority, 'Y (China)', in his grounds of appeal and subsequently provided the Tribunal with fabricated internet printouts to support the fake citation. When challenged, counsel initially maintained the case was genuine before later admitting to the use of AI without verification. The Tribunal found that counsel failed to act with honesty and integrity, attempted to mislead the court, and breached professional duties. Consequently, the Tribunal referred Mr. Rahman to the Bar Standards Board (BSB) for investigation, noting that his conduct contributed to the wrongful prolonging of litigation and wasted public resources.

Operational lesson

Handing the Panel ChatGPT-fabricated 'Y (China)' printouts triggered BSB referral — ban consumer AI from appellate immigration bundles.

Record details

CourtImmigration and Asylum Chamber
Jurisdictioninternational
CircuitNot recorded
DateAug 12, 2025
CH
AI toolChatGPT
Party typeLawyer
OutcomeCounsel was referred to the Bar Standards Board (BSB) for professional investigation.
Known amountNot recorded
Professional sanctionReferral to the Bar Standards Board (BSB) for investigation.
Attribution boundary

What the record establishes about AI use

admitted

Counsel admitted to using ChatGPT for drafting and research.

Procedural posture

Upper Tribunal (Immigration and Asylum Chamber) hearing to determine whether to refer counsel to the Bar Standards Board following the submission of AI-generated false 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 a non-existent Court of Appeal authority 'Y (China)' as though it dealt with undue weight on delay; Tribunal found the case does not exist and was generated by ChatGPT.
  2. Fabricated: Exhibits & Submissions | Printed material handed to the Panel comprised internet printouts with misleading statements referencing the fictitious 'Y (China)' and mis-associating it with the citation for YH (Iraq).

Questions this record answers

What happened in MS (Bangladesh)?
The Upper Tribunal referred counsel to the Bar Standards Board (BSB) for investigation after he repeatedly relied on ChatGPT to generate and defend a fabricated legal authority ('Y (China)') in immigration proceedings, failing to perform mandatory verification checks and attempting to mislead the Tribunal regarding the source of his research.
Why does MS (Bangladesh) matter for legal AI risk?
Handing the Panel ChatGPT-fabricated 'Y (China)' printouts triggered BSB referral — ban consumer AI from appellate immigration bundles.
What does the public record establish about MS (Bangladesh)?
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 MS (Bangladesh) 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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