I'm not sure that I understand the legal distinction between mandatory and directory, but nevertheless the GA Sup Ct had this to say yesterday about the word "shall". Nonetheless, Parlor contends that the wording of OCGA Â§ 15-12-40 (a) (1) that the jury list â€œshallâ€ be updated at least biennially makes that task mandatory for the board of jury commissioners, rather than directory. However, the word â€œshallâ€ was present in the statutes involved in this Courtâ€™s prior decisions, see Burney, supra; Haden, supra, and we remain convinced that the provision is directory. http://www.gasupreme.us/pdf/s06a1861.pdf This interpretation was used to reinstate an indictment that had been quashed by the trial court because it was issued by an unlawfully constituted grand jury, as a result of the jury list not having been revised in time. I am no particular scholar on the word "shall", but I can observe that we on this board place a great deal of importance on that word in the statute regarding licensure. It has been argued in GCO filings as well. I suppose what is perhaps concerning as well is that the GA Sup Ct refuses in this case to impose any penalties on the judiciary when it fails to abide by a "shall" in the code. What then is the impetus for bothering to update the grand jury list per the code, or to issue GFLs per the code for that matter?