Sanction teardown · Upper Tribunal (Immigration and Asylum Chamber), UK · 2026-06-12
Habib & Anor v Secretary of State for the Home Department
What happened
In Upper Tribunal (Immigration and Asylum Chamber), UK, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:
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Misrepresented (Case Law)AH (Sudan) was cited for a flexible approach to obtaining documents from countries with weak or disrupted state structures, but the Tribunal found that the case was not authority for that proposition.
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Misrepresented (Case Law)Matusha was cited for a contextual approach to Afghan evidence, although it concerned an Albanian deception case and did not support the proposition advanced.
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False Quotes (Case Law)The words “contextual and nuanced” were placed in quotation marks as if taken from Matusha, but the Tribunal found that neither word appeared in the judgment.
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Misrepresented (Case Law)A case described as AA (Afghanistan) was cited to support the same proposition, but the citation led to AA (Nigeria), which contained no support for it.
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Fabricated (Case Law)A purported DNA and paternity case was cited as [2023] UKUT 00121, but the Tribunal could find only PW v Secretary of State for Work and Pensions [2023] UKUT 121 (AAC), an unrelated non-IAC case.
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Misrepresented (Case Law)Bracking v SSWP was cited as authority concerning procedural unfairness, but the case concerned different issues and was not authority for that proposition.
Which AI tool
an unnamed/unconfirmed AI tool. 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
Appeal dismissed; solicitors and counsel issued a notice to show cause concerning possible wasted costs and referral to the SRA/BSB. No professional sanction or monetary penalty was imposed in this decision.
Additional detail
The Upper Tribunal identified multiple incorrect, misleading, and apparently fabricated authorities in the appellants’ grounds of appeal and amended skeleton argument. It found that AH (Sudan), Matusha, and AA (Nigeria) did not support the propositions for which they were cited, and that the alleged quotation from Matusha did not appear in that judgment. Other citations appeared to correspond to unrelated cases or could not be located. The court considered that an AI large language model may have been used, but this was not established. It directed the solicitors and counsel to explain the drafting, any AI use, and their citation checks, reserving questions of wasted costs and regulatory referral.
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.
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Source: https://www.damiencharlotin.com/documents/3029/UI-2026-000882___UI-2026-000883.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).