The Upper Tribunal has ruled that two immigration solicitors will be probed by the SRA for use of fake case citations in two separate judicial review applications. Across both cases, grounds and supporting materials contained fictitious cases which had been generated using non-legal specialist AI tools.
Handing down her judgment on 17 November 2025, Judge Lindsey highlighted the vigilance required by legal professionals in the age of generative and search-engine AI. More broadly, Judge Lindsey maintains that “any legal practitioner who commences or pursues proceedings in a court or tribunal owes certain obligations to it”. AI’s presence in the legal world only compounds this. The inclusion of fake cases and moreover the general failure to check these by supervising solicitors, have clearly undermined these obligations and shines an unwanted spotlight on the profession as a whole.
Judge Lindsey also drew attention to the responsibilities of senior fee-earners when supervising junior colleagues. She highlighted how supervising solicitors are more culpable than the individual that they are supervising. There is also a clear duty on this individual to ensure that they develop their juniors meaningfully and in doing so, maintain professional standards.
Comment
This judgment is two-fold. While Judge Lindsey is clear in her criticism of the Defendants’ failure to ensure that the documents were correct before signing the statements of truth, this case is illustrative of the growing impact of AI on the legal profession.
Crucially, Judge Lindsey’s judgment is not anti-AI. Instead, she acknowledges the clear benefits of legal AI programmes used by trained legal professionals and ultimately, how their use represents a huge step forward for the profession. Namely, their ability to streamline legal research and condense otherwise onerous disclosure exercises into bitesize chunks. The use of such technology has the potential to revolutionise the experience for both clients and lawyers alike. For example, if used appropriately, such programmes can reduce time spent on administrative tasks, thus providing increased efficiency and a reduction in operational costs. It also has the power to simplify data processing by organising large datasets across various search criteria.
Judge Lindsey also notes the vital importance of understanding AI’s pitfalls in order for its potential to be fully realised. She notes the scope for AI to make “confident assertions that are simply untrue” based on the prompts provided by the user. While this comment shines a light on the responsibility of legal professionals to check the credibility of AI-sourced information, such risks are not solely limited to those within the profession. Use of incorrect information from generative AI tools from litigants in person has scope to create false confidence in those with little-to-no legal knowledge or experience in navigating the court system. In doing so, this can dissuade LIPs from instructing solicitors and leave them exposed to serious cost risks in the court in the event that they opt to run with a matter themselves.
Additionally, Judge Lindsey notes that the use of confidential information being plugged into open-source AI tools is akin to placing information on the internet in the public domain and thus breach client confidentiality and waive legal privilege.
Conclusion
AI’s growing influence in the legal profession is undeniable.
While it would be all too easy to trot out the “with great power comes great responsibility” proverb, Judge Lindsey reminds us that if used correctly, AI has the ability to empower solicitors, clients and alter the legal landscape. It’s therefore essential that legal professionals treat it with the respect that it deserves.
