The Tribunal’s decision dated 25 August 2026 is subject to appeal to the High Court (Administrative Court) by the Respondent. The Order remains in force pending the High Court’s decision on the appeal.

The Applicant alleged that on 19 August 2020 the Respondent knowingly employed an adult disqualified from employment by reason of immigration status, resulting in a criminal conviction under section 21(1) and (2) Immigration, Asylum and Nationality Act 2006. The SRA relied on the Respondent’s conviction, dated 29 January 2024, as evidence that the Respondent was guilty of the offence and relied upon the findings of fact upon which that conviction was based as proof of those facts. The signed Certificate of Conviction was dated 7 March 2025.

The SRA also relied on the Respondent’s sentence of a 12-month Community Order, with unpaid work requirement of 150 hours, dated 26 April 2024 as evidence that the Respondent was guilty of that offence and relied upon the admission and acceptance of the sentence as proof of the facts. Dishonesty was not alleged; it was sufficient that the offence was committed knowingly. Allegation 1.1 was proved and the Respondent was ordered to be struck off the register of Registered Foreign Lawyers.

The Applicant alleged that while defending the Rule 12 proceedings the Respondent filed submissions and correspondence containing incorrect, fabricated, misleading or unsupported authorities, quotations and legal propositions arising from the use of generative artificial intelligence (AI). He was alleged to have done this in his Answer to the Rule 12 Allegation dated 12 March 2026 and in email correspondence with the Applicant dated 9 April 2026. The Applicant alleged breaches of Principles 1, 2 and 5 and paragraphs 1.4 and 2.4 of the Code.

The Respondent admitted the presence of inaccurate citations and legal assertions of principle and accepted that he had used AI tools and made consequent errors. He denied any intention to mislead and cited ill-health and stress in mitigation. Dishonesty was not alleged. Allegation 2.1 was proved; Allegation 2.2 was proved in respect of the citing of non-existent cases and incorrect legal propositions. Typographical errors in case citations were not sufficiently serious to amount to misconduct. The Respondent was ordered to be struck off the register of Registered Foreign Lawyers.

This was the first time that a lawyer’s use of artificial intelligence or large language models in legal proceedings had been litigated before the Tribunal. The High Court, in the matter of Ayinde v Haringey LBC [2025] EWHC 1383 (Admin), had invited the legal regulatory bodies to consider, as a matter of urgency, what further steps, beyond issuing guidance, needed to be taken to address this problem. The SRA considered, and the Tribunal accepted, that this was an issue of profound public importance, relating to the proper role of lawyers and the effect that artificial intelligence and large language models could have on the administration of justice and exercise of the rule of law in this jurisdiction.