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AK v Secretary of State for the Home Department

Court
Upper Tribunal
Jurisdiction
UK
Decided
2025-10-06
AI tool
ChatGPT
Outcome
Show Cause Order
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Grounds of appeal cited 'R (Goudey) v SSHD [2012] EWHC 567 (Admin)'; Judge found the authority does not exist and treated it as another example of AI-generated false citation. || Fabricated: Case Law | Grounds of appeal cited 'Nye v SSHD [2021] EWCA Civ 148'; Judge found the authority does not exist and linked it to unchecked generative-AI drafting.

Details

The grounds of appeal contained at least two non-existent authorities. The judge concluded the false citations likely arose from unchecked generative-AI drafting and directed the solicitor to show cause why conduct should not be referred to the SRA.

Sanction teardown · Upper Tribunal, UK · 2025-10-06

AK v Secretary of State for the Home Department

What happened

In Upper Tribunal, UK, a filing relied on ChatGPT to help draft legal argument. The court identified the following problems with the citations in that filing:

  • Fabricated (Case Law)
    Grounds of appeal cited 'R (Goudey) v SSHD [2012] EWHC 567 (Admin)'; Judge found the authority does not exist and treated it as another example of AI-generated false citation.
  • Fabricated (Case Law)
    Grounds of appeal cited 'Nye v SSHD [2021] EWCA Civ 148'; Judge found the authority does not exist and linked it to unchecked generative-AI drafting.

Which AI tool

ChatGPT. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Show Cause Order

Additional detail

The grounds of appeal contained at least two non-existent authorities. The judge concluded the false citations likely arose from unchecked generative-AI drafting and directed the solicitor to show cause why conduct should not be referred to the SRA.

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/901/UI2025002918.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/901/UI2025002918.pdf

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