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Incident Tracker / United Kingdom

Folarin v Immigration Services Commissioner, [2026] UKFTT 135 (GRC)

·First-tier Tribunal (General Regulatory Chamber)·UKDismissal

Before the First-tier Tribunal (General Regulatory Chamber), immigration adviser Raphael Folarin, appealing the loss of his registration, cited multiple non-existent authorities obtained by asking ChatGPT for supporting cases and editing summaries he never verified. The tribunal dismissed his appeal, finding the fabricated citations confirmed his unfitness, and noted such conduct may amount to contempt.

Court
First-tier Tribunal (General Regulatory Chamber)
Date
2026-01-29
Who used the AI
Not recorded
AI tool
ChatGPT
Conduct
A self-represented immigration adviser appealing the loss of his registration cited multiple authorities the tribunal could not locate in any legal database. He disclosed asking ChatGPT to identify the top cases supporting his arguments, then edited the summaries without reading the underlying judgments.
Outcome
Dismissal
Penalty
No monetary penalty recorded
Regulatory outcome
No separate regulatory disposition recorded
Status
Verified against listed sources
Last checked
2026-09-11

What was fabricated or misused

  • A number of decided cases in the legal-framework section of Mr Folarin’s witness statement — no or inaccurate citations and no copies were provided, and the panel could not locate several in any database

What the court said

“In presenting his case, and in particular in the section of his witness statement dealing with the legal framework, Mr Folarin referred to a number of decided cases in support of his points.”
First-tier Tribunal (General Regulatory Chamber), [28]
“He accepted that he had not read the judgments in the underlying cases and had used ChatGPT to provide him with a summary so he could understand what they say.”
First-tier Tribunal (General Regulatory Chamber), [28]
“This would have had the effect of misleading the Tribunal had the Tribunal not challenged the point.”
First-tier Tribunal (General Regulatory Chamber), [49]
“Had Mr Folarin already been registered and conducted his case in such a way, the Tribunal would have needed to consider reporting him to the IAA in any event.”
First-tier Tribunal (General Regulatory Chamber), [51]

Timeline

  1. Mr Folarin and DSN Global Immigration Lawyers applied for Level 1 immigration and asylum registration.
  2. The Commissioner refused registration and Mr Folarin appealed the same day.
  3. The tribunal heard the appeal by Cloud Video Platform and questioned the AI-sourced authorities.
  4. The tribunal dismissed the appeal and found Mr Folarin not currently fit to provide immigration advice.

Why this case matters

Folarin adds a UK regulatory-registration setting rather than litigation sanctions. Unlike Huish v HMRC, where the tribunal recorded fake cases but attached no blame to a litigant in person, the General Regulatory Chamber treated unverified AI case-law use as evidence of fitness for an immigration adviser. It also connects Ayinde's High Court guidance to a non-lawyer adviser applicant: the tribunal accepted there was no intent to mislead but still found a risk to vulnerable advice seekers if similar methods were used in practice.

Practice note

An adviser applicant using AI should file only authorities he has personally opened, read and supplied to the tribunal. If a case comes from ChatGPT or a legal portal, verify the judgment in a recognised database and keep the copy. Do not rely on AI summaries in place of the judgment text, especially where fitness turns on honesty, compliance and professional judgement.

Primary sources for this incident

Related regulation records for this incident

No related regulation record has been linked to this incident yet.

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Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Folarin v Immigration Services Commissioner, [2026] UKFTT 135 (GRC)”, safelegalai.com/tracker/folarin-v-immigration-services-commissioner (accessed 2026-09-16). Data: CC BY 4.0.

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