During an Immigration search of a Fish & Chip shop in February 2025, Officers found an illegal migrant worker on the premises. A Civil Penalty Notice in the sum of £40,000 was issued to the business owner under Section 15 of the Immigration, Asylum and Nationality Act 2006.
The owner lodged an appeal. Keoghs were instructed by the Secretary of State for the Home Department (SSHD) to defend the appeal. File handler Lucy Boyle led on this matter, under the supervision of Khuram Ahmed. We considered the SSHD to have a strong case and began preparing for the appeal hearing.
When the appellant’s Solicitor filed and served a Skeleton Argument, Counsel identified several mis-citations and a potential hallucination of legal authorities. This is to say, the citations he referenced either did not exist or were completely made up. Lucy Boyle made enquires with the appellant’s Solicitors and requested copies of the authorities relied upon. After some initial resistance, they provided an explanation claiming that the citations were drawn from secondary practitioner material and repeated in error.
Keoghs were not satisfied with this explanation. A formal letter was sent to the appellant’s Solicitor taking issue with the authorities and citations in the Skeleton Argument. We went further and prepared a statement for the court expressing serious concern that the appellant had used generative AI to prepare their Skeleton Argument and had relied upon hallucinated authorities.
Surprisingly, the appellant responded by seeking to withdraw the entire appeal. Neither Keoghs nor the court accepted this course of action. The court noted that a preliminary issue arose of whether the appellant’s solicitors had misled the court and whether there had been an abuse of the court’s process, with reference to R (Ayinde) v The London Borough of Haringey & Ors [2025] EWHC 1383. This issue was to be heard before the main appeal.
The appellant’s solicitors made further attempts to withdraw the appeal and even offered to pay the SSHD’s cost. They informed the court that they had referred themselves to the SRA. Both Keoghs and SSHD were firm in that this issue needs to be heard by the court.
It came to light that a second individual, Mr Malik, a part-time worker at the solicitors, had provided the false authorities relied upon. The court adjourned the first hearing in December 2025 to allow the appellant’s solicitor to respond to the allegations. Mr Rasheed, the supervising solicitor, submitted further evidence outlining a substantial portion of research and collation of draft authorities was undertaken by Mr Malik. Mr Rasheed accepted full responsibility.
During the time between the first and final hearing, the appellant found himself in more hot water:
Immigration solicitors to face SRA probe over fake AI-generated case citations | Law Gazette
In the period between the first and final hearings, the matter attracted wider attention when it was reported that Mr Rasheed had also been found to have used AI generated citations in a separate case, R (Munir) v SSHD, and had been referred to the SRA as a result. This development was duly referenced by Keoghs Counsel in the Skeleton Argument for the present proceedings. Notably, Mr Rasheed had not brought the proceedings in Munir to the attention of the court in the present case, nor had he cross-notified the court in Munir of the present proceedings.
The hearing was listed for 23 March 2025, Peter Saville of 4-5 Gray’s Inn Square was instructed to represent the SSHD and posed the following to the Judge:
1) Whether the court consider there to be prima facie evidence of a contempt and whether it is in the public interest to issue contempt proceedings?
2) If not, what proportion of costs should Mr Rasheed and City Law pay as wasted costs?
Counsel made submissions highlighting the timeline of both the current proceedings and the proceedings in R (Munir) v SSHD. The hearing in Munir took place on 5 November 2025, crucially only one day before the appellant in the present case sought to withdraw the Appeal via a Consent Order on 6 November 2025. At the time of the hearing in Munir, an order for directions had already been made in the present proceedings concerning the issue of authorities. This order was produced in October, before the hearing in Munir on 5 November 2025.
In Munir it was determined that ‘Mr Rasheed demonstrated a worrying lack of understanding of the extent to which AI is available in the modern world’. Further that ‘there appears to be every likelihood that Mr Malik will have worked on other unidentified files for the firm and may have relied on false citations which were generated by AI, as Mr Rasheed accepted he had done in this case’.
Mr Rasheed’s barrister accepted that his client should have been more candid about the ongoing proceedings, and that the matters developing in Munir should have been brought to the attention of the SSHD. It was confirmed that Leap Software had been used in the preparation of the Skeleton Argument, but not to find the cases relied upon. Those cases were found by Mr Malik and supplied to Mr Rasheed.
Mr Rasheed accepted that the threshold for a wasted costs order had been met, therefore the only issue remining for this hearing was to determine the amount of wasted costs.
The Judge determined that by accepting that the Skeleton Argument contained false material presented as genuine, Mr Rasheed had engaged in improper, unreasonable, and negligent conduct, which has caused the SSHD to incur unnecessary costs. A wasted costs order was accordingly made.
The costs of the underlying appeal were ordered to be paid by the Appellant, and a wasted costs order was made against Mr Rasheed directly.
Given the serious nature of a wasted costs order, the court was required to inform the SRA. It was ordered that the court would now transfer the issue of Mr Rasheed’s conduct to the High Court under its jurisdiction concerning the administration of justice.
Authors:
Lucy Boyle – File Handler
Khuram Ahmed – Technical Support Lawyer
The service you deliver is integral to the success of your business. With the right technology, we can help you to heighten your customer experience, improve underwriting performance, and streamline processes.
