This case highlights how the growing us of modern technology including artificial intelligence can pose real risks, especially in relation to child protection.

What happened in this case?

Former supply teacher Abusali Rahman, 37, of Salford, Greater Manchester, was jailed for six years at Bolton Crown Court after admitting 21 child sex offences. These offences included ‘upskirting’ offences and generating AI images using photographs of the school pupils.

The court heard 15 girls, aged 13 to 16, were targeted at seven secondary schools in Bolton, Bury and Salford. Police said 12 had been identified. He used an iPhone concealed in his top pocket to secretly photograph pupils during lessons. He also followed girls walking upstairs to take upskirt photographs at the schools where he worked.

Rahman had been working at various schools and colleges in the Northwest of England since 2022. During this time, he had used his position as a teacher to find information about pupils so he could locate them on social media and use their own photos to create sexualised images using AI technology. He then went on to share the AI images and upskirting images online.

He was caught when the mother of one girl was scrolling on X and came across an image of her daughter in her school uniform next to graphic sexual images.

During the investigation, the police located a document he had created which promoted the sale of female sexual content online for a one-time payment of £20.

His offending was described as "gross breach of trust".

Image based abuse

Image based abuse has gained significant media attention in recent years particularly following the case of Stephen Bear and Georgia Harrison.

In 2019, ‘upskirting’ was made a specific criminal offence with the Voyeurism Act coming into force. Upskirting’ is an informal term for a type of voyeurism when someone uses equipment like a camera or mobile phone to take photos or videos underneath a person’s clothes, without their permission.

The use of AI to create ‘deep fakes’

The use of artificial intelligence (AI) is growing rapidly in all areas of modern life. This technology can also be used to create or change images, videos, or audio recordings; abusers are using this technology to create sexual images and child sexual abuse material.

The fast-growing nature of this is evidence in a UNICEF, ECPAT and INTERPOL study across 11 countries, which states at least 1.2 million children disclosed having had their images manipulated into sexually explicit deepfakes in the past year. In some countries, this represents 1 in 25 children, the equivalent of one child in a typical classroom.

Psychological Impact

It is important to recognise that even though in cases of upskirting and AI generated deepfakes, there has not been any physical contact, and the victims may not even be aware at the time, the psychological effects can be significant.

Especially in a case such as this one, where the perpetrator was a teacher that these pupils trusted and that they were safe in a school environment.

Is there an option for a civil claim?

For anyone who has been a victim of voyeurism offences, pursuing a civil claim provides an opportunity to seek compensation for the harm that has been suffered.

It is possible to bring a civil case for voyeurism offences; these claims can be brought for a breach of privacy and there may be a personal injury claim if there has been a psychological impact.

These claims can be complex and every case is different. Whether a claim is possible will be assessed based on the individual facts, evidence and legal principles. Our team can listen to your circumstances, explain the potential options available and advise whether you may have grounds for a civil compensation claim. You do not need to be certain that you have a claim before seeking advice.

We understand the importance of survivors being aware of their options and regaining their power by making their own decisions.

How can Switalskis help?

Every survivor of abuse deserves justice. This not only includes the abuser’s taking accountability for their crimes, but for the survivors to find their voice, take back control and access compensation for the harm they have suffered.

At Switalskis, our specialist abuse lawyers have decades of experience in representing survivors of child sexual exploitation. We understand that such cases are very emotional for clients and are often legally complex, therefore we are dedicated to providing a supportive and professional environment in which our clients can feel confident in our services. We are committed to ensuring our clients receive the compensation they deserve.

If you have been impacted and would like to discuss your experience in confidence, our specialist abuse team can help. Call 0808 258 8041 or email help@switalskis.com  .