UK Barrister Found Using AI to Generate Fictitious Legal Cases
An immigration barrister was found by a judge to have used AI software to prepare legal research for a tribunal hearing, citing cases that were "entirely fictitious" or "wholly irrelevant." The barrister failed to verify the accuracy of the citations and reportedly tried to hide his use of AI.
What happened
Immigration barrister Chowdhury Rahman used ChatGPT-like software to prepare his legal research for a tribunal hearing in an asylum appeal case involving two Honduran sisters.
Upper tribunal judge Mark Blundell found that 12 authorities were cited in Rahman's grounds of appeal, but some of those authorities did not exist and others did not support the propositions of law for which they were cited.
Blundell stated: 'The most obvious explanation is … that the grounds of appeal were drafted in whole or in part by generative artificial intelligence such as ChatGPT.' The judge noted that one of the cases cited had 'recently been wrongly deployed by ChatGPT in support of similar arguments.'
Reported impact
Judge Blundell found that Rahman 'failed thereafter to undertake any proper checks on the accuracy' of the AI-generated content and had 'wasted' the tribunal's time.
Blundell stated that 'not one decision supported the proposition of law set out in the grounds' and rejected Rahman's appeal, finding nothing in his submissions established an error of law.
Index analysis
The AI system generated multiple fictitious legal cases and citations that did not exist, demonstrating a hallucination failure mode that the barrister did not catch before submitting to the court.
Rahman apparently tried to hide his use of AI and misled the court about the source of his legal research by claiming he had used 'various websites.'
Governance controls
Judge Blundell said he was considering reporting Rahman to the Bar Standards Board for disciplinary action.
Classification
Sources and evidence
Sources not yet published
This record was researched and written by the Index from original reporting. Its sources are still being verified by an editor, and they are listed here once that check is complete. Until then the record carries no reviewer.