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On 12 November 2025, the Qatar Financial Centre (QFC) Civil and Commercial Court delivered a landmark judgment in the case of Jonathan David Sheppard v Jillion LLC. The case has attracted significant attention due to the citation of ‘fake cases’ in submissions to the Court. The judgment not only addresses the specific conduct in question but also sets out broader guidance for legal professionals and clients alike, particularly regarding the use of artificial intelligence (AI) and secondary sources in legal research.

Access the judgment

Background: the facts of the case

The dispute arose from an employment claim brought by Jonathan David Sheppard against Jillion LLC. During the proceedings, the defendant’s legal representative, an unnamed Dubai-based lawyer, submitted an application for an extension of time to file a defence. In support of the application, the lawyer cited several apparent cases, including “Al Khor International School v. Gulf Contracting Co. (QFC 2022)” and “Doha Bank v. KPMG (QFC App 2019)”.  

However, when the Court Registry ordered the legal representative to provide copies of the judgements, it became apparent that the cases did not exist. The lawyer initially claimed difficulty accessing the judgments on the Court’s website but later admitted, via a witness statement, that the references were included in error due to reliance on secondary sources.

The Court’s findings

The QFC Court concluded the lawyer’s conduct amounted to a breach of Article 35.2 of the Rules and Procedures of the Civil and Commercial Court, which prohibits providing false or misleading information to the Court. The Court determined that the conduct was intentional because the lawyer had persisted in referencing the fake cases even after being challenged by the Registry. The Court found the lawyer had committed a contempt of court.

However, the Court decided not to impose a penal sanction on the lawyer. Instead, it accepted the lawyer’s apology and determined that the publication of the judgment itself would serve as a sufficient deterrent to future conduct of this kind. The Court also chose to anonymise the lawyer’s identity, noting that public identification would be a disproportionately harsh penalty given the size of the legal profession practicing in the GCC.

The use of AI in litigation

The judgment situates the problem of ‘fake cases’ within a global context. The Court referred to the widely publicised US case of Mata v Avianca Inc (2023), where lawyers relied on AI-generated, non-existent cases in court submissions. Similar issues have arisen in England and Wales, Canada, and Australia, prompting courts and regulators to issue guidance on the responsible use of AI and the necessity of verifying legal authorities.

The QFC Court acknowledged that AI and digital tools can enhance legal research, reducing costs and increasing efficiency. However, it emphasised that lawyers have a professional duty to verify the accuracy of any authorities cited, whether found via AI, internet searches, or traditional research methods.

Practical implications for legal practitioners

• The key lesson from this case is the absolute necessity for lawyers to verify the existence and content of any case law or authority cited in court.
• Reliance on secondary sources, incomplete databases, or AI-generated content without proper verification is not acceptable and may result in findings of contempt or professional misconduct.
• The QFC Court announced that a draft Practice Direction would be published alongside the judgment. This Practice Direction will require all advocates before the Court to verify any case or authority cited, with sanctions, including public identification and disgrace, for breaches.
• The submission of fake cases can have serious consequences, not only for the lawyers involved but also for their clients. Courts may disregard arguments based on non-existent authorities, potentially weakening a client’s position.

Final thoughts

The judgment in Jonathan David Sheppard v Jillion LLC serves as a timely warning to the legal profession and clients alike. The use of fake cases, whether intentional or through careless reliance on AI and secondary sources, will not be tolerated by the QFC Court. Legal practitioners must ensure that all authorities cited are genuine and properly verified.

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