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MS (Bangladesh)

Court
Immigration and Asylum Chamber
Jurisdiction
UK
Decided
2025-08-12
AI tool
ChatGPT
Outcome
Referred to the Bar Standards Board for investigation
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Grounds of appeal cited a non-existent Court of Appeal authority 'Y (China)' as though it dealt with undue weight on delay; Tribunal found the case does not exist and was generated by ChatGPT. || Fabricated: Exhibits & Submissions | Printed material handed to the Panel comprised internet printouts with misleading statements referencing the fictitious 'Y (China)' and mis-associating it with the citation for YH (Iraq).

Details

Underlying judgment (in which the hallucination had been observed) is here.

Sanction teardown · Immigration and Asylum Chamber, UK · 2025-08-12

MS (Bangladesh)

What happened

In Immigration and Asylum Chamber, 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 a non-existent Court of Appeal authority 'Y (China)' as though it dealt with undue weight on delay; Tribunal found the case does not exist and was generated by ChatGPT.
  • Fabricated (Exhibits & Submissions)
    Printed material handed to the Panel comprised internet printouts with misleading statements referencing the fictitious 'Y (China)' and mis-associating it with the citation for YH (Iraq).

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

Referred to the Bar Standards Board for investigation

Additional detail

Underlying judgment (in which the hallucination had been observed) is here.

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/806/305.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/806/305.pdf

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