Incident Tracker / United Kingdom
UK v Secretary of State for the Home Department (AI hallucinations; supervision; Hamid), [2026] UKUT 81 (IAC)
·Upper Tribunal (Immigration and Asylum Chamber)·UKRegulatory referral
Before the Upper Tribunal (Immigration and Asylum Chamber), two immigration matters featured fabricated authorities traced to AI, including Google's AI results. Solicitor and COLP Zubair Rasheed was referred to the Solicitors Regulation Authority for failing to supervise the caseworker who drafted fake citations; a separate adviser escaped referral by self-reporting to his regulators.
- Court
- Upper Tribunal (Immigration and Asylum Chamber)
- Date
- 2025-11-17
- Who used the AI
- Not recorded
- AI tool
- Google AI
- Conduct
- Two immigration matters featured fabricated authorities traced to AI, including Google's AI results. In one, grounds drafted by a caseworker cited four non-existent cases; in the other an adviser cited a fictitious authority. The tribunal stressed the risk is not confined to generative models such as ChatGPT.
- Outcome
- Regulatory referral
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- Solicitors Regulation Authority: Solicitor and COLP Zubair Rasheed was referred to the SRA for failing to supervise the caseworker who drafted the fake citations. A separate adviser, Tahir Mohammed, escaped referral by self-reporting to the Immigration Advice Authority and the SRA before the tribunal acted. (2025-11-17)
- Status
- Verified against listed sources
- Last checked
- Not separately recorded
What was fabricated or misused
- Horleston v SSHD [2007] EWCA Civ 654 — no reported case called Horleston; the citation was for South Tyneside Metropolitan Borough Council v Anderson & Others
- R (Dzineku-Liggison) v SSHD [2020] EWHC 3386 — High Court citation and stated fee-waiver proposition were wrong
- Patel (mandatory refusal – fairness) [2011] EWCA Civ 811 — tribunal could not find that authority
- R (Muhandiramge) v SSHD [2010] EWHC 2568 (Admin) — no Administrative Court decision with that citation or name
- OE (Nigeria) [2010] UKUT 35 (IAC) — no such reported Upper Tribunal case or citation existed
What the court said
“The danger in using Artificial Intelligence for legal research is not confined to generative AI models such as ChatGPT, therefore; the use of Google AI for legal research is equally likely to generate results which are false but which might initially be thought to be accurate.”
“It matters not how such citation errors come about. Whether they are inserted by a hapless trainee or by ChatGPT is really neither here nor there; the point is that the qualified legal professional with conduct of the matter is expected to ensure that such documents are checked, that errors are identified, and that only accurate documents are sent to the tribunal.”
“we consider that the inclusion of false citations in the grounds for judicial review and Mr Rasheed’s failure to supervise the work undertaken by his brother in this and an unknown number of other cases necessitates a referral to the SRA.”
“The claim form by which judicial review is sought in the Upper Tribunal has now been amended so as to require a legal representative to confirm by a statement of truth that any authority cited within the form or in any documents appended to it (a) exists; (b) may be located using the citation provided; and (c) supports the proposition of law for which it is cited.”
Timeline
- TMF grounds of appeal were drafted with the false Horleston citation.
- CLP judicial-review grounds were dated with four authorities later challenged.
- UTJ Blundell refused permission and ordered the COLP to identify the author.
- Tribunal issued a show-cause notice in the Horleston matter.
- Mr Mohammed self-reported to the IAA and SRA.
- Relisted Hamid hearing took place; only Mr Rasheed attended.
- Tribunal decision referred Mr Rasheed to the SRA and made no further referral for Mr Mohammed.
Why this case matters
UK v SSHD turns Ayinde from warning into tribunal administration. It is broader than MS Bangladesh because it covers a regulated adviser, a solicitor-COLP, a junior caseworker and Google AI, not only ChatGPT. The decision also changed the tribunal's judicial-review claim form so representatives must certify that authorities exist, are locatable by citation and support the point made. That turns verification into a signed filing obligation and makes supervision the centre of the misconduct analysis.
Practice note
The solicitor or adviser signing the form must run the citation check personally or supervise a documented check before filing. The check should confirm three things: the case exists, the citation locates it, and the authority supports the proposition. Staff also need clear instructions that Google AI and public ChatGPT are not legal research sources for tribunal filings.
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
Similar incidents on the record
- Cork & Anor v Smith, [2026] EWHC 1199 (Ch)2026-05-22 · High Court of England and Wales (Business and Property Courts, Insolvency and Companies List) · Regulatory referralIn the High Court (Insolvency and Companies List), Pinsent Masons LLP quoted a fabricated version of Insolvency Rule 12.37(5) — text that does not exist — after a junior solicitor used an AI system that hallucinated the…
- MS (Professional conduct, AI generated documents) Bangladesh, [2025] UKUT 305 (IAC)2025-08-12 · Upper Tribunal (Immigration and Asylum Chamber) · Regulatory referralBefore 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 Pre…
- Ayinde v London Borough of Haringey; Al-Haroun v Qatar National Bank2025-06-06 · High Court of England and Wales (Divisional Court) · Regulatory referralThe landmark England and Wales ruling on AI-fabricated citations: in joined cases, the Divisional Court invoked the Hamid jurisdiction over submissions containing non-existent authorities, referred a barrister to the BS…
- SRA v Abhishek Kumar, Case No. 12884-2026 (SDT)2026-08-25 · Solicitors Disciplinary Tribunal · Strike-off / disbarmentIn the United Kingdom, the Solicitors Disciplinary Tribunal struck Registered Foreign Lawyer Abhishek Kumar off the register after he used generative AI to file false citations and misleading quotations in his defence t…
Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “UK v Secretary of State for the Home Department (AI hallucinations; supervision; Hamid), [2026] UKUT 81 (IAC)”, safelegalai.com/tracker/uk-v-sshd-2026-ukut-81 (accessed 2026-09-16). Data: CC BY 4.0.