Angelika Hellweger discusses the latest instance of a lawyer being caught out by fake cases, generated by large language models. Consequences for this type of misuse are likely to become more severe.
Another instance has emerged of a lawyer relying on fake cases generated by large language model tools. This time, the court dealing with the issue was the Qatar Financial Centre Civil and Commercial Court.
The case is Jonathan David Sheppard v Jillion LLC [2025] QIC (E) 3
The court protected the lawyer’s anonymity in this instance, but issued a warning to all lawyers using the Qatar International Court and Dispute Resolution Centre.
In future, any citation of any case or other authority to the Court which has not been verified by the advocate will be considered a breach of the conduct and will be sanctioned accordingly. The sanctions will include the full identification of the lawyer or law firm and the consequent public disgrace.
The Qatar Financial Centre Civil and Commercial Court is now drafting a Practice Direction to set out the approach that litigators must adopt.
Facts of the case
In support of an applications for an extension of time, and in a submission for a jurisdictional challenge, a lawyer cited the cases: Doha Bank v. KPMG (QICDRC App 2019), and Al Khor International School v. Gulf Contracting Co. (QFC 2022)
The lawyer relied on the cases to prove that:
- “extensions are granted for exceptional circumstances”
- “fairness and proportionality override rigid deadlines”; and
- “jurisdiction is interpreted narrowly and cannot be presumed where connection to QFC is tenuous.”
The claimant requested a copies of the cases, when he was not able to find them.
In response, the lawyer said that he was unable to access judgment copies of the cases on the website of the court.
The Registry ordered the lawyer to provide a witness statement to explain how he came across the two cases. In the witness statement the lawyer admitted that the references were made in error. He blamed “wrong research.” Later he admitted that he relied on a Google search, and the AI summaries it generates.
The Court’s reaction
The Court had little sympathy for the lawyer relying on cases provided by an AI system, particularly in circumstances where the lawyer had failed to check the existence of the case. This amounted to reckless conduct. The situation was made worse by the lawyer’s attempts to disguise his actions. Only after two further requests by the Registry did the lawyer admit that the cases were provided by Google. This was deemed to be a contempt of court.
However, the court accepted an apology as sufficient penalty this time. They also anonymised the identity of the lawyer to protect his professional reputation.
The Qatari Court was lenient this time, as it was the first occasion on which fake cases had been cited to it. But it will not be lenient in future. The Practice Direction will set out the standards expected form lawyers when using AI.
Comparison with the UK
The UK Courts have also had to issue warnings to lawyers for using unchecked research generated by AI models.
On 6 June 2025 the Administrative Court issued leading judgment on this point in Ayinde v London Borough of Haringey, and Al-Haroun v Qatar National Bank [2025] EWHC 1383 (Admin)
The two cases were listed together under the court’s Hamid jurisdiction1. That jurisdiction relates to the court’s inherent power to regulate its own procedures and to enforce duties that lawyers owe to the court.
In this instance, the lawyers were ordered to pay wasted costs for citing cases that did not exist.
The potential consequences of relying on fake cases in the UK courts are:
- Referral to the police for a criminal investigation
This is only applicable in the most egregious cases. However, deliberately placing false material before the court with the intention of interfering with the administration of justice amounts to the common law criminal offence of perverting the course of justice, carrying a maximum sentence of life imprisonment.
- Contempt of court
- Referral to regulator for breaching regulatory requirements
- Strike out and costs sanctions:
A wasted costs order may be appropriate for placing false material before the court with the intention of the court treating it as genuine. It is improper and unreasonable and negligent conduct.
- Public admonishment
Comment
This latest case serves as another warning to the legal industry about relying on generative AI. All cases and other sources must be checked through reputable channels such as the National Archives database, the official law reports, and databases of reputable legal publishers.
The consequences of failing to do so are likely to only become more severe.
Source
- From R (Hamid) v Secretary of State for the Home Department [2012] EWHC 3070 (Admin) [2013] CP Rep 6
