Incident Tracker / Gulf states
Sheppard v Jillion LLC [2025] QIC (E) 3 (CTFIC0033/2025)
·Qatar Financial Centre Civil and Commercial Court (First Instance Circuit)·GULFOther
In this Qatar Financial Centre Civil and Commercial Court judgment, President Lord Thomas found an anonymised Dubai-based lawyer in contempt for citing two fake QFC cases sourced from Google and persisting after challenge, breaching Article 35.2. The court imposed no penal sanction, treating the apology and publication of the judgment as sufficient.
- Court
- Qatar Financial Centre Civil and Commercial Court (First Instance Circuit)
- Date
- 2025-11-12
- Who used the AI
- Not recorded
- AI tool
- Not identified in the record
- Conduct
- A Dubai-based lawyer, acting on an extension-of-time application, cited two non-existent QFC authorities. He first claimed he could not access the judgments online, then admitted the citations came from Google search screenshots. President Lord Thomas of Cwmgiedd found the conduct intentional, not inadvertent, and a contempt of court under Article 35.3.
- Outcome
- Other
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- Not separately recorded
What was fabricated or misused
- Al Khor International School v. Gulf Contracting Co. (QFC 2022) — not a decision of the QFC Civil and Commercial Court
- Doha Bank v. KPMG (QFC App 2019) — not a decision of the QFC Civil and Commercial Court
- Doha Bank v. KPMG (QICDRC App 2019) — repeated jurisdiction-challenge citation to the same non-existent authority
What the court said
“This judgment relates to the citation by a lawyer in these proceedings of what purported to be decisions of the Qatar Financial Centre Civil and Commercial Court (the ‘Court’) but which in fact were not, now usually referred to as ‘fake cases’.”
“… provide the Registry with a copy of each case that the Defendant and their legal representative have referred to in the emails they have sent to the Registry, namely: “Al Khor International School v. Gulf Contracting Co. (QFC 2022)” and “Doha Bank v. KPMG (QFC App 2019)”, no later than 16.00 (Doha time) on Tuesday 30 September 2025.”
“It is difficult to see how any lawyer could, by the second half of 2025 be under any doubt as to the necessity of checking that a case provided by an AI system is in fact a decision set out in the jurisprudence of the court.”
“In these circumstances, the Court does not accept that the conduct was inadvertent. It amounted to intentional conduct. There was plainly no reasonable excuse.”
Timeline
- Defendant's lawyer applied for more time and cited Al Khor and Doha Bank.
- A later preliminary defence repeated Doha Bank for a jurisdiction challenge.
- Registry ordered the lawyer to provide copies of both authorities.
- The lawyer said the cases came from Google search screenshots.
- The lawyer sent a written submission maintaining inadvertence and apologising.
- Court found contempt and breach of Article 35.2 but imposed no penal sanction.
Why this case matters
Sheppard adds a Gulf court response to the pattern seen in Ayinde v Haringey and Mata v Avianca. The QFC court treated the false authorities as contempt, even though the lawyer said he relied on Google screenshots and acted for a friend. The court then chose anonymity and no penal sanction because it was the first such case before that court, while warning that future advocates may be named. The record is also useful because it applies verification duties to a cross-border lawyer outside Qatar.
Practice note
An advocate before the QFC court must read the cited authority itself before relying on it. A search screenshot or AI answer is not enough. If the Registry asks for a case, the lawyer should either produce the judgment and neutral citation immediately or withdraw the citation and explain how it entered the filing.
Primary sources for this incident
Related regulation records for this incident
Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “Sheppard v Jillion LLC [2025] QIC (E) 3 (CTFIC0033/2025)”, safelegalai.com/tracker/sheppard-v-jillion-qfc (accessed 2026-09-16). Data: CC BY 4.0.