[2025] UKUT 00305 (IAC)

MS (Professional conduct; AI generated documents) Bangladesh

Field House,

Breams Buildings

London, EC4A 1WR

Hearing date: 23rd July 2025

Promulgated: 12th August 2025

Before:

THE HON. MR JUSTICE DOVE

UPPER TRIBUNAL JUDGE LINDSLEY

Between:

MS (Bangladesh)

(ANONYMITY ORDER MADE)

Appellant

- and -

SECRETARY OF STATE FOR THE HOME DEPARTMENT

Respondent

1. AI large language models such as ChatGPT can produce misinformation including fabricated judgments complete with false citations.

2. The Divisional Court has provided guidance in the case of R (Ayinde) v London Borough of Haringey, Al-Haroun v Qatar National Bank QPSC [2025] EWHC 1383 (Admin) that the consequence of using AI large language models in a way which results in false authorities being cited is likely to be referral to a professional regulator, such as the BSB or SRA, as it is a lawyer’s professional responsibility to ensure that checks on the accuracy of citation of authority or quotations are carried out using reputable sources of legal information. Where there is evidence of the deliberate placing of false material before the Court police investigation or contempt proceedings may also be appropriate.

3. Taking unprofessional short-cuts which will very likely mislead the Tribunal is never excusable.

HAMID J U D G M E N T

Judge Lindsley: