Sanction teardown · Upper Tribunal (IAC), UK · 2025-09-29
ANPV and SAPV v Secretary of State for the Home Department
What happened
In Upper Tribunal (IAC), UK, a filing relied on Microsoft Copilot to help draft legal argument. The court identified the following problems with the citations in that filing:
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Fabricated (Case Law)The cited Honduras country-guidance authority did not exist. The purported decision was not found, and the alternative authorities produced by counsel concerned Pakistan or an interim order and did not support claims about systemic fear and impunity in Honduras.
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Fabricated (Case Law)The cited Eritrea authority did not exist. The substitute case, BF (Eritrea) v SSHD, concerned interpretation of administrative policies and did not address section 8 credibility considerations.
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Misrepresented (Case Law)The authority existed but was misrepresented as establishing trauma-informed principles for evaluating fragmented or emotionally charged testimony. The court found that it concerned the use of plausibility in credibility assessments and did not support the ground.
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Misrepresented (Case Law)The citation identified the Court of Appeal decision, but counsel produced the Supreme Court decision instead. Neither decision supported the proposition advanced concerning documentary evidence.
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Misrepresented (Case Law)The case was cited as supporting a section 8 argument about plausible, fear-based decisions under threat. The court held that JT (Cameroon) was the leading section 8 authority but did not support the proposition made in the grounds.
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Misrepresented (Case Law)The case name and citation did not match: [2020] UKSC 9 was MS (Pakistan) v SSHD, a human-trafficking case, not SC (Protection), and it did not concern internal relocation.
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Misrepresented (Case Law)The authority was used to support the proposition that cumulative past harm could sustain ongoing risk, but the cited paragraphs merely recounted case history and witness evidence and contained no such holding.
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Misrepresented (Case Law)The authority concerned the best interests of children in an extradition context and did not support the Article 3 ECHR proposition advanced in the grounds. The judge noted that Article 3 was not even mentioned in the relevant judgment.
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Misrepresented (Case Law)R (YH) v SSHD was cited for a section 8 credibility argument, but the case concerned fresh protection claims and paragraph 353 of the Immigration Rules and was accepted to be irrelevant.
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Misrepresented (Case Law)The citation belonged to AM (Cameroon), not AM (Afghanistan). The actual case concerned procedural impropriety and did not introduce feasibility standards for internal relocation.
Which AI tool
Microsoft Copilot. 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
Order to Show Cause
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/3249/ANPV_v._SAPV_United_Kingdom_29-09-2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).