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Justice Matrix · Case profile

MS v Secretary of State for the Home Department (Professional Conduct: AI Generated Documents) Bangladesh

UK Upper Tribunal (Immigration and Asylum Chamber)2025
Needs review
Needs review

Machine-found from the cited source, not yet confirmed by a human. Open the source before relying on it.

Strategic issue

What was at stake

The decision addresses professional conduct concerns arising from AI‑generated documents in a Bangladeshi asylum case.

Key holding

What the court decided

The Upper Tribunal held that a barrister had cited a non-existent authority ("Y (China) [2010] EWCA Civ 116") in grounds of appeal that he had drafted using ChatGPT, maintained the fake citation was genuine when challenged (handing up a printout of false references), and had failed to verify it against reputable legal sources such as Bailii, Westlaw or LexisNexis. The Tribunal ruled this conduct breached the barrister's professional duties of honesty and integrity and was not excused by illness or time pressure, holding that using AI in a way that produces false authorities is a serious professional failing. The disposition was a referral of the barrister to the Bar Standards Board (his second such referral); the Tribunal did not grant the individual relief on the merits of the immigration appeal in this reported professional-conduct decision.

Issue areas

Categories

immigrationasylumhuman-rights
Source

Authoritative link

Source of record
https://caselaw.nationalarchives.gov.uk/ukut/iac/2025/305
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