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Incident Tracker / United Kingdom

MS (Professional conduct, AI generated documents) Bangladesh, [2025] UKUT 305 (IAC)

·Upper Tribunal (Immigration and Asylum Chamber)·UKRegulatory referral

Before the Upper Tribunal (Immigration and Asylum Chamber), barrister Muhammad Mujeebur Rahman cited a fabricated Court of Appeal case, Y (China), drafted using ChatGPT without verification. The tribunal, led by its President Mr Justice Dove, referred him to the Bar Standards Board for breaching duties of honesty, integrity and competence.

Court
Upper Tribunal (Immigration and Asylum Chamber)
Date
2025-08-12
Who used the AI
Not recorded
AI tool
ChatGPT
Conduct
Counsel drafted grounds of appeal citing a fabricated Court of Appeal authority, Y (China) [2010] EWCA Civ 116, using ChatGPT and carried out no verification against reputable legal databases. He admitted using ChatGPT both when drafting the grounds and during the hearing.
Outcome
Regulatory referral
Penalty
No monetary penalty recorded
Regulatory outcome
Bar Standards Board: The Upper Tribunal, presided over by its President Mr Justice Dove, referred barrister Muhammad Mujeebur Rahman to the Bar Standards Board for investigation, finding he had breached professional duties of honesty, integrity and competence. (2025-08-12)
Status
Verified against listed sources
Last checked
2026-09-16

What was fabricated or misused

  • Y (China) [2010] EWCA Civ 116 — no such Court of Appeal case exists
  • Nine stapled pages handed to the tribunal on 20 June 2025 — not a Court of Appeal judgment and containing references to fictitious Y (China) with the citation for YH (Iraq)

What the court said

“The case Y (China) does not exist.”
Upper Tribunal (Immigration and Asylum Chamber), [4]
“Mr Rahman has accepted that he used ChatGPT on two occasions: when he drafted the original grounds of appeal and when he appeared before the Upper Tribunal Panel.”
Upper Tribunal (Immigration and Asylum Chamber), [11]
“We find therefore that Mr Rahman has directly attempted to mislead the Tribunal through reliance on Y (China), and has only made a full admission of this fact in his third explanation to the Upper Tribunal.”
Upper Tribunal (Immigration and Asylum Chamber), [12]
“We do however conclude that this is a case where referral to a regulator, in this instance the BSB, is most definitely appropriate.”
Upper Tribunal (Immigration and Asylum Chamber), [17]

Timeline

  1. Grounds of appeal drafted with the false Y (China) citation.
  2. Upper Tribunal hearing; counsel defended Y (China) after using ChatGPT over lunch.
  3. Counsel wrote that he had meant to cite YH (Iraq).
  4. Hamid hearing; counsel admitted using ChatGPT for the grounds and hand-up.
  5. Upper Tribunal promulgated decision referring counsel to the BSB.

Why this case matters

MS Bangladesh applies the Divisional Court's Ayinde guidance inside immigration tribunal proceedings soon after that judgment. Unlike Bandla v SRA, it involved practising counsel and an admitted use of ChatGPT during both drafting and the hearing. The tribunal found that the false case may have affected permission to appeal, then used the Hamid process to send the matter to the Bar Standards Board rather than contempt or police action. It shows how a single fabricated citation can become a regulatory case when explanations shift after a judge asks for the source.

Practice note

Counsel should not cite an authority generated by ChatGPT unless it has been opened and checked in a reputable legal source such as BAILII, Westlaw, EIN or LexisNexis. If a judge asks for the case, the answer should be the verified judgment or an immediate correction. A later attempt to recast a fake case as a typo increased the tribunal's concern here.

Primary sources for this incident

Related regulation records for this incident

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Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “MS (Professional conduct, AI generated documents) Bangladesh, [2025] UKUT 305 (IAC)”, safelegalai.com/tracker/ms-bangladesh-2025-ukut-305 (accessed 2026-09-16). Data: CC BY 4.0.

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