Tokenizer Fertility and Zero-Shot Performance of Foundation Models on Ukrainian Legal Text: A Comparative Study

Tokenizer fertility varies 1.6x across foundation models on Ukrainian legal text, yet this cost-critical dimension is absent from model selection practice. We benchmark seven models from five providers on 273 validated court decisions from Ukraine's state registry (EDRSR), measuring tokenizer fertility and zero-shot performance on three tasks. Four findings emerge. (1) Qwen 3 models consume 60% more tokens than Llama-family models on identical input, making tokenizer analysis a prerequisite for cost-efficient deployment. (2) NVIDIA Nemotron Super 3 (120B) achieves the highest composite score (83.1), outperforming Mistral Large 3 (5.6x more total parameters) at one-third the API cost model scale is a poor proxy for domain performance. (3) Few-shot prompting degrades performance by up to 26 percentage points; stratified and prompt-sensitivity ablations confirm this is intrinsic to Ukrainian-language demonstrations, not an artifact of example selection. (4) A cross-temporal generalization experiment reveals that classifiers trained on pre-war court ecisions (2008-2013) lose 27.9 percentage points when applied to full-scale invasion era decisions (2022-2026), with a pronounced forward-backward asymmetry: newer models transfer backward (+14.6 pp above forward transfer), but older models fail catastrophically on wartime legal language. For practitioners: tokenizer analysis should precede model selection, and zero-shot is a more reliable default than few-shot for morphologically rich languages. To support reproducibility and address the absence of Ukrainian from legal NLP benchmarks, we release a public dataset of 14,452 court decisions spanning 2008-2026, annotated with seven outcome labels across three temporal epochs that capture the impact of armed conflict on judicial proceedings.