MS (Bangladesh)
Immigration and Asylum Chamber · Aug 12, 2025
- Jurisdiction
- international
- Court
- Immigration and Asylum Chamber
- Record ID
- ms-bangladesh-2025-08-12
- Observed outcome
- Counsel was referred to the Bar Standards Board (BSB) for professional investigation.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
Handing the Panel ChatGPT-fabricated 'Y (China)' printouts triggered BSB referral — ban consumer AI from appellate immigration bundles.
Failure modes and consequences
- Fake Citations
- Immigration
- Trial
- Bar Referral
- Professional
- AI attribution
- Admitted
- Recorded tool
- ChatGPT
- Known monetary consequence
- Not recorded
- 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.
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
Counsel admitted to using ChatGPT for drafting and research.
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
- Mandate the use of reputable legal databases (e.g., Bailii, Westlaw) for all citation verification, prohibiting reliance on generative AI for case law research.
- Implement a formal sign-off process for all court submissions to ensure every cited authority has been independently verified by a qualified practitioner.
- Establish clear internal policies regarding the disclosure and use of AI tools in legal drafting and research.
- Require practitioners to inform the Tribunal immediately if they are unable to perform their duties due to health or other personal circumstances, rather than resorting to unverified research.