Jonathan David Sheppard v Jillion LLC

What the order says

“1. Contempt of court and breach of article 35.2 of the Rules and Procedures of the Civil and Commercial Court of the QFC proved. 2. There be no penal sanction.”

Two numbered lines, and nothing else in the operative part. Article 35.2 is contravened where a person, without reasonable excuse, engages in conduct intended to obstruct the Court in the exercise of its powers, including by giving information that is false or misleading. Article 35.3 gives the Court its enforcement powers: fines, any order it considers necessary in the interests of justice, and referral to a competent agency or authority of the State. None of the three was used.

The timeline

• 29 Sep 2025An employment claim. At 13:29 a lawyer practising outside Qatar, acting for the defendant, applies by email for an extension of time to serve a defence, on the ground that the defendant’s principal, Mr Usman Ali, required hospitalisation. The application cites two decisions of this Court, Al Khor International School v. Gulf Contracting Co. and Doha Bank v. KPMG. Neither exists. At 17:06 a further submission cites Doha Bank again, this time on jurisdiction.
• 30 Sep, 06:01The claimant, acting in person, is the one who notices. He emails the Court asking for the neutral citation of Doha Bank v. KPMG, because he cannot find it.
• 30 Sep, 08:52The Registry orders the lawyer to produce a copy of each case by 16:00 that day.
• 30 Sep, 10:03He replies that he is “unable to access judgement copies of the cases on the website of court” and asks the Court to disregard them.
• ThenOrdered to produce the cases or a witness statement with a statement of truth, he files one attributing the citations to “copy paste errors and wrong research” and to “reliance on secondary sources / incomplete case law databases”. He apologises.
• 1 Oct 2025Asked where he found them, he produces screenshots of a Google search, explaining he had been helping a friend while in India, late at night. The screenshots are reproduced in the judgment.
• 8 to 22 OctThe matter is referred for formal determination under article 35. He maintains the conduct was inadvertent, tenders a full apology, and asks the Court to view the episode through the lens of proportionality.
• 12 Nov 2025Judgment. Contempt proved, no penal sanction. A draft of the Practice Direction is published for consultation the same day.

Why the Court found intention

Contravention of article 35.2 requires a requisite intention, and the Court applied the test from its own earlier decision, Ferris v Sanguine Investment Management [2024] QIC (E) 1. Two paragraphs carry the reasoning.

“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. Proceeding therefore to refer to such a case without making such a check ordinarily amounts to reckless conduct, not caring whether there was or was not such a case.”

That is paragraph 23, and on its own it describes recklessness rather than intention. The Court then says the conduct “goes further”, and what took it further was not the citation. It was the answer given when the Registry asked for the citations: that the judgments could not be accessed on the Court’s website. Only after two further requirements did the lawyer disclose that the cases had come from a Google search.

So the finding turns on what happened after the mistake. The Court did not accept that the conduct was inadvertent, held it to be intentional with no reasonable excuse, and found the contempt made out on that basis.

Why no penalty, and why no name

The Court held that the apology tendered and the publication of the judgment would be sufficient penalty and a sufficient deterrent. It then considered whether to anonymise the lawyer and concluded, in its own words, “not without very considerable hesitation”, that identification would be a disproportionately harsh penalty given the nature and size of the legal profession practising within the states of the GCC, and given that this was the first case of its kind before this Court.

The judgment carries an anonymity warning on its face: revealing the identity of the anonymised individual would itself be a contempt. We do not identify them, and no reader should attempt to.

First, and last. Paragraph 26 says what the direction to follow would mean:

“… any citation of any case or other authority to this Court which has not been verified by an examination by the advocate of the case or other authority, will be considered a breach of the conduct required of all advocates before the Court and sanctioned accordingly. The sanctions will include the full identification of the lawyer or law firm and the consequent public disgrace.”

The case and the instrument are one act

At paragraph 19 the Court explains why an instrument was needed. This Court publishes all its decisions on a freely available and searchable website, and its case law is far less extensive than most, so fake citations of its own decisions should not have occurred at all. Then, in the same sentence, the welcome:

“Although the use of artificial intelligence is to be welcomed in litigation with its potential to reduce cost and promote greater effectiveness, it is clear that a Practice Direction is required to set out the approach that litigators before this Court, as in other courts, must adopt.”

A draft of that direction was published for consultation at the same time as the judgment. It issued as Practice Direction No. 1 of 2026 on 6 January 2026, signed by the same President. Paragraph 4 of the direction is that welcome, and its footnote points back to this paragraph 19. Read the two documents together and the sequence is unusually clean: a court finds the failure, states the standard, and writes the rule in one movement.

The Court also surveyed the problem elsewhere before deciding, quoting Mata v. Avianca at length and Ayinde at paragraphs 7 to 9, and noting that Canadian and Australian matters are collected in Ayinde. It noted that in England and Wales the equivalent work is done by the Hamid jurisdiction, and that in this Court it is done by article 35.

What this case contributes

• The findingA contempt can be established while no penalty is imposed. On this record it is the clearest instance of a court separating the two questions, and it is why the finding, not the fine, is the thing to carry into practice.
• The triggerThe disclosure failure, not the citation, is what moved this from recklessness to intention. The account given to the Registry did more damage than the fake cases.
• Who caught itA self-represented claimant, by 06:01 the next morning. Verification is not only what an opponent’s counsel does.
• The standardParagraph 23 fixes a date. From the second half of 2025, not checking is not a defence in this Court.
• What comes nextParagraph 26 removes the anonymity for anyone who follows, and names public identification as part of the sanction.

Sources

• Sealed judgment, [2025] QIC (E) 3, 12 November 2025, QICDRC, read in full. An Arabic text is published alongside.
• Case page, CTFIC0033/2025
• Rules and Procedures before the Civil and Commercial Court of the QFC, for article 35.
• Practice Direction on the Use of Artificial Intelligence (No. 1 of 2026), the instrument this judgment produced.
• The lawyer is anonymised by order of the Court, which warns that identification would itself be a contempt. We do not name them.

Related

• The full sanctions record
• Qatar, the practice direction this case produced, read paragraph by paragraph
• Mata v. Avianca and Ayinde v Haringey, both relied on in this judgment
• Zhang v Chen, among the Canadian matters the Court noted
• Every verified AI standing order

Checked 27 August 2026 against the sealed judgment as published by the QICDRC, read in full. Information, not legal advice, and not advice on QFC practice.