The Qatar Financial Centre Civil and Commercial Court has issued a clear warning on the misuse of artificial intelligence and online research in litigation, after a lawyer practising in Dubai cited two non-existent QFC authorities in Jonathan David Sheppard v Jillion LLC ([2025] QIC (E) 3). The Court found both a contravention of article 35.2 of its Rules and Procedures and a contempt of court, although no penal sanction was imposed.

Lawyer Cites Non-Existent QFC Precedents

The issue emerged in what began as a routine employment claim. The Registry had ordered the Defendant to serve a Defence. On 29 September 2025, at 13:29, the Defendant’s lawyer emailed an application for an extension of time, relying on the illness and hospitalisation of the Defendant’s principal. In support, he cited provisions of the QICDRC Rules and two supposed QFC decisions, said to relate to extensions of time and the overriding of rigid deadlines.

A further email at 17:06 on the same day advanced a preliminary Defence and jurisdictional challenge, again invoking a precedent said to concern the narrow interpretation of the Court’s jurisdiction.

The Claimant, acting in person, asked the Court the next morning to direct the Defendant to provide the neutral citation for the supposed precedent, as he had been unable to locate it. The Registry then ordered the lawyer to provide copies of both cases by 16:00 on 30 September 2025. At 10:03 that morning, he stated that he was unable to access the judgments on the Court’s website and asked that the references be disregarded. When required to provide a witness statement explaining how he had come upon the cases and the propositions of law they supported, he stated that they had been included “inadvertently due to copy-paste errors and wrong research” and reliance on “secondary sources / incomplete case law databases.” He apologised and maintained that the error was inadvertent.

On 1 October 2025, when asked where he had found the named cases, he said that they had appeared in a search, attaching Google screenshots, and explained that he had been helping the Defendant’s principal “as a friend” during late hours while in India. He again apologised.

Court Finds Contempt – But Spares the Name (This Time)

The Court determined that the lawyer’s conduct should be formally addressed under article 35 of the Rules and Procedures. Lord Thomas of Cwmgiedd held that the lawyer had engaged in conduct intended to obstruct the Court by giving false and misleading information, contrary to article 35.2, and that this amounted to contempt of court under article 35.3, applying the approach to intention previously set out in Ferris v Sanguine Investment Management [2024] QIC (E) 1.

The Court said, no lawyer could be in doubt as to the need to verify that any case produced by an AI system or online search is an authentic decision. The QFC publishes all its judgments on a freely accessible website and has a relatively limited body of case law; the reference to fictitious authorities “should not have occurred.” In the Court’s view, the conduct could not be regarded as inadvertent; it amounted to intentional behaviour without reasonable excuse.

However, “not without very considerable hesitation”, the Court concluded that the apology already tendered and the publication of the judgment were a sufficient penalty and deterrent. It decided that identifying the lawyer would inflict a disproportionately harsh penalty, given the nature and size of the legal profession in the GCC and the fact that this was the first case of its kind before the Court. No penal sanction was therefore imposed, and the lawyer was anonymised.

Intentional Misconduct, Not Inadvertence

The Court treated the matter as a formal misconduct issue under article 35. Lord Thomas of Cwmgiedd held that the lawyer had given false and misleading information with the intention of obstructing the Court, in contravention of article 35.2, and that this conduct amounted to contempt under article 35.3. In reaching that conclusion, the Court applied the approach to intention previously set out in Ferris v Sanguine Investment Management [2024] QIC (E) 1.

Leniency Because This Was The First Case

Despite those findings, the Court paused before imposing any sanction. It considered that identifying the lawyer would inflict a disproportionately harsh penalty in the relatively small GCC legal market and noted that this was the first occasion on which such conduct had arisen before the QFC Court. “Not without very considerable hesitation”, the Court held that the apology already offered, together with the publication of the judgment itself, would suffice as both penalty and deterrent. No fine was imposed and the lawyer was anonymised.

Part Of A Global Trend

The judgment deliberately situates Qatar within a wider international trend. Lord Thomas referred to Mata v Avianca Inc in the United States, where lawyers submitted AI-generated authorities, and to R (on the application of Ayinde) v London Borough of Harringay [2025] EWHC 1383 (Admin) in England and Wales, in which Dame Victoria Sharp stressed that advocates who use AI remain personally responsible for verifying their research against authoritative sources. The Court also mentioned similar incidents in Canada and Australia.

New Practice Direction: Verify Or Face Public Sanction

Alongside the judgment, the Court has indicated that it will issue a draft Practice Direction on the use of AI and the citation of authorities. It confirms that any case or other authority relied upon must be verified by the advocate’s own examination. Any future citation of unverified or fabricated authorities will be treated as a breach of the conduct expected of advocates and will attract sanctions, including the identification of the lawyer or firm and the resulting public disgrace.

For practitioners, the message is clear. AI may speed up research, but it does not dilute the advocate’s personal responsibility for the accuracy and integrity of what is put before the Court.