Insights
26th November 2025
Upholding Legal Integrity: Lessons from the Qatar International Court on AI-Generated Citations.
This judgment issued by the Qatar International Court and Dispute Resolution Centre concerns the conviction of a lawyer for contempt of court and breach of its rules after he cited fabricated court decisions and fictitious cases generated by artificial intelligence or unreliable sources in his submissions.
The Court had requested the lawyer to provide copies of the two cases, based on the request of the opposing party in the proceedings. However, the lawyer asked the Court to disregard this request, claiming he was unable to obtain copies of the judgments.
To reaffirm its request, the Court required clarification, and the lawyer subsequently submitted a written statement in which he admitted to an unintentional mistake due to “reliance on secondary sources/incomplete case law databases by error.” He also provided screenshots from a Google search, which demonstrated that the information he had cited resulted from an inaccurate search.
Accordingly, after reviewing and examining the facts, the Court concluded the following (as it mentioned in the Judgment:
- 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. In the present case the conduct goes further in that when the Registry asked for the citations, the Dubai Lawyer stated that he was unable to access judgment copies of the cases on the Court's website. It was only after two further requirements made by the Registry did the Dubai lawyer admit that the cases were provided by Google in the screenshots set out above.
- In these circumstances, the Court does not accept that the conduct was inadvertent. It amounted to intentional conduct. There was plainly no reasonable excuse. The Dubai Lawyer therefore acted in contravention of article 35.2 and committed a contempt of court under article 35.3.
- However, despite these findings and the circumstances set out, the Court considers that the apology tendered and the publication of this judgment will be a sufficient penalty and act as a sufficient deterrent to future conduct of this kind before this Court. In this particular case, the Court has considered whether it should anonymise the identity of the lawyer. The Court has concluded, not without very considerable hesitation, that identifying the Dubai lawyer would inflict on him a disproportionately harsh penalty given the nature and size of the legal profession practising within the states of the GCC and given that this is the first case where this has happened in this Court.
- However, as the Practice Direction will make clear, 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.
- This case underscores the importance of professional diligence and accuracy when citing legal authorities, including AI-generated sources. The Court’s ruling highlights that lawyers bear full responsibility for verifying the validity of cases and references they present. The publication of this judgment serves both as a warning against reliance on unverified information and as a guide to uphold integrity and accountability in legal practice
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