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In the ever-developing world of generative AI, and after cases concerning the citation of fake cases by lawyers emerged in the United States, England, Australia and other jurisdictions over the course of the last year or so, it was perhaps inevitable (albeit certainly avoidable) that such an incident would arise in the Qatar International Court, more commonly known as the QFC Court.
On 12 November 2025, the QFC Court handed down a judgment in contempt proceedings against a Dubai-based lawyer (who acted for the defendant in the underlying case, Jonathan David Sheppard v Jillion LLC) ("the Lawyer"), finding that the Lawyer had acted in contempt of court by citing fake cases in his submissions. Having found the Lawyer guilty of contempt, the QFC Court did not impose any penal sanction.
The facts of the case are simple: the Lawyer relied on an AI tool (screenshots of the research were provided to the QFC Court), which appears to have been the default AI function in Google (commonly known as Gemini), to conduct his research for case law in support of the Defendant's application for an extension of time to serve the Defence. His research identified two QFC cases, which ultimately proved to be non-existent: "Al Khor International School v. Gulf Contracting Co. (QFC 2022)" and "Doha Bank v. KPMG (QFC App 2019)".
When asked by the Claimant and the QFC Court for a copy of these judgments, the Lawyer was unable to tender them. Nor was he able to provide any reasonable explanation as to why he could not locate and submit these judgments. Ultimately, the Lawyer had no option but to tender unconditional apologies to the QFC Court, citing the error in citation as "inadvertent".
After giving the Lawyer a chance to explain himself, the QFC Court found that his citation of the fake cases was not an inadvertent error; rather, it was "intentional conduct". The QFC Court reprimanded the Lawyer in serious terms, including that it was inconceivable for any lawyer not to verify the case law citations produced by an AI tool with the actual body of case law published by the QFC Court. Importantly, the QFC Court noted that its case law is accessible for free on its helpful and user-friendly website. Indeed, as the QFC Court acknowledged, the case law is not as extensive as it may be in other, more established jurisdictions. There was, therefore, no reason why the Lawyer would not have been able to cross-check the case law references generated by the AI tool.
The Lawyer was found guilty of contempt of court under Article 35.2 of the Court Rules. However, given that this was the first such case in the QFC, and that the Lawyer had pleaded the adverse consequences of penal sanctions on his broader legal practice, the QFC Court found it sufficient retribution that the Lawyer had apologised and that the judgment was made public (albeit with the Lawyer's identity anonymised).
Moving forward, however, it is unlikely that the QFC Court will adopt a lenient approach to sanctions for similar conduct, including the revelation of the identities of lawyers or firms that cite fake cases. A very clear message has been sent by the QFC Court: whilst the use of AI is inevitable and indeed encouraged, this judgment should act as a deterrent for all practitioners in the QFC Court, particularly as to the serious consequences that could follow from blindly following AI-generated information.
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