MS (Professional conduct; AI generated documents) Bangladesh [2025] UKUT 00305 (IAC)

1. AI large language models such as ChatGPT can produce misinformation including fabricated judgments complete with false citations.

2. The Divisional Court has provided guidance in the case of R (Ayinde) v London Borough of Haringey, Al-Haroun v Qatar National Bank QPSC [2025] EWHC 1383 (Admin) that the consequence of using AI large language models in a way which results in false authorities being cited is likely to be referral to a professional regulator, such as the BSB or SRA, as it is a lawyer’s professional responsibility to ensure that checks on the accuracy of citation of authority or quotations are carried out using reputable sources of legal information. Where there is evidence of the deliberate placing of false material before the Court police investigation or contempt proceedings may also be appropriate.

3. Taking unprofessional short-cuts which will very likely mislead the Tribunal is never excusable.