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discipline 30 September 2026

The duty in context

No conflict between current clients client

The lawyer must not act for two or more current clients with conflicting interests except within defined exceptions with each client's informed consent and protection of confidentiality.

1,282 cases 61% strike-off avg suspension 17.6 mo avg fine 138,302 623 with dishonesty finding

How the codes express this duty

E&W Solicitors SRA Principles & Code CCS 6.2 strong 841 cases
6.2 You do not act in relation to a matter or particular aspect of it if you have a conflict of interest or a significant risk of such a conflict in relation to that matter or aspect of it, unless: (a) the clients have a substantially common interest ...; or the clients are competing for the same objective, and the conditions below are met ...
E&W Barristers BSB Handbook rC21.3; gC69 strong 29 cases
rC21.3 there is a conflict of interest, or real risk of conflict of interest, between the prospective client and one or more of your former or existing clients in respect of the particular matter unless all of the clients who have an interest in the particular matter give their informed consent to your acting in such circumstances;
Cayman Islands Legal Services Code 2026 R.7.1; R.7.2; R.7.3 strong
Except in the limited circumstances dealt with in R.7.3, an attorney-at-law or a recognised law entity shall not act if there is a conflict of interests or a significant risk of a conflict... may act, in non-contentious matters, for more than one client whose interests conflict in the matter only with the informed written consent of all clients.
AU Solicitors Solicitors' Conduct Rules Rules 11.1; 11.2; 11.3; 11.4 strong 126 cases
11.1 A solicitor and a law practice must avoid conflicts between the duties owed to two or more current clients. 11.2 If a solicitor or a law practice seeks to act for two or more clients in the same or related matters where the clients' interests are adverse and there is a conflict or potential conflict... the solicitor or law practice must not act, except where permitted by Rules 11.3 and 11.4.
AU Barristers Uniform Barristers Rules r113 strong 38 cases
A barrister who is briefed to appear for two or more parties in any case must determine as soon as possible whether the interests of the clients may, as a real possibility, conflict and, if so, the barrister must then return the brief for: (a) all the clients in the case of confidentiality to which Rule 108 would apply; or (b) one or more of the clients so as to remove that possibility of conflict.
IE Solicitors Law Society Guide Ch3 — General; Conflict of interest between two clients; Non-conveyancing transactions strong 50 cases
A solicitor should not act in a matter, or any part of a matter, where there is a conflict of interest... If a solicitor, acting with ordinary care, would give different advice to different clients about the same matter, there is a conflict of interest, and the solicitor should not act for both clients... Where clients consent to one firm representing both parties to a non-conveyancing transaction, the law requires that each client gives informed consent.
IE Barristers Bar Code of Conduct Rule 3.16; Rule 10.10 partial 50 cases
In cases involving several parties, Barristers on receipt of instructions for more than one of such parties should consider whether or not any conflict arises as between the individual interests of each of the clients and they shall advise the solicitor as to whether any of the clients should be separately advised and represented by a Barrister or solicitor. ... Barristers may appear for more than one defendant in a criminal trial provided they have satisfied themselves that there is no conflict of interest.
JM Attorneys Canons of Professional Ethics Canon IV(k); Canon IV(l); Canon IV(m) strong 125 cases
Subject to the provisions of Canon IV (l), an Attorney shall not accept or continue his retainer or employment on behalf of two or more clients if their interests are likely to conflict or if the independent professional judgment of the Attorney is likely to be impaired. (l) Notwithstanding the provisions of Canon IV (k), an Attorney may represent multiple clients if he can adequately represent the interests of each and if each consent to such representation after full disclosure of the possible effects of such multiple representation.
JE Lawyers Law Society of Jersey Code R.6.1; R.6.3 strong
Except in the limited circumstances dealt with in R.6.3, a member or their firm must not act if there is a conflict of interests or a significant risk of a conflict... A member or their firm may act, in non-contentious matters, for more than one client whose interests conflict in the matter only with the informed written consent of all clients.
ON Lawyers LSO Rules of Prof. Conduct r 3.4-2; r 3.4-3 strong
3.4-2 A lawyer shall not represent a client in a matter when there is a conflict of interest unless there is consent, which must be fully informed and voluntary after disclosure, from all affected clients and the lawyer reasonably believes that he or she is able to represent each client without having a material adverse effect upon the representation of or loyalty to the other client. [3.4-3 Despite rule 3.4-2, a lawyer shall not represent opposing parties in a dispute.]
BC Lawyers BC Code r 3.4-2 strong 35 cases
A lawyer must not represent a client in a matter when there is a conflict of interest unless there is express or implied consent from all clients and the lawyer reasonably believes that he or she is able to represent each client without having a material adverse effect upon the representation of or loyalty to the other client.
NZ Lawyers Conduct & Client Care Rules r 6.1 strong
A lawyer must not act for more than 1 client on a matter in any circumstances where there is a more than negligible risk that the lawyer may be unable to discharge the obligations owed to 1 or more of the clients.
SCO Solicitors LSS Standards of Conduct B1.7 strong 55 cases
You must not act for two or more clients in matters where there is a conflict of interest between the clients or for any client where there is a conflict between the interest of the client and your interest or that of your practice unit.
SG Lawyers Professional Conduct Rules 2015 r 20 (Conflict, or potential conflict, between interests of 2 or more clients) strong 8 cases
20 Conflict, or potential conflict, between interests of 2 or more clients
HK Solicitors Solicitors' Guide Principle 9.01 strong
A solicitor or firm of solicitors must not accept instructions to act for two or more clients where there is a conflict or a significant risk of conflict between the interests of those clients.
HK Barristers Bar Code of Conduct para 10.14(a) strong
If after he has accepted the brief or instructions on behalf of more than one lay client, there is or appears to be a conflict or a risk of conflict between the interests of any one or more of such clients, he must not continue to act for any client unless all such clients give their consent to his so acting and he can do so without embarrassment.

Cases dealing with this duty

Clear

1,282 decisions · link basis: found breached = a tribunal finding; rule cited = the mapped provision is cited in the decision; text match = high-precision text pattern

  • Gary Ackinclose
    SDT solicitor 11786/2018 2018-01-01 found breached

    Breaches

    Strike off 1 PDF View decision
  • Jonathan Horner
    SDT solicitor 11905/2018 2018-01-01 found breached

    Breaches, Failures

    Strike off 1 PDF View decision
  • Babatunde Adegboyega Taiwo
    SDT solicitor 11836/2018 2018-01-01 found breached

    Breaches

    Strike off 1 PDF View decision
  • Michael Kenneth Smith
    SDT solicitor 11877/2018 2018-01-01 found breached

    Breaches, Failures

    Strike off 1 PDF View decision
  • Ashton Lloyd Doherty
    SDT solicitor 11874/2018 2018-01-01 found breached

    Breaches, Failures

    Strike off 1 PDF View decision
  • Edward Sibley
    SDT solicitor 11780/2018 2018-01-01 found breached

    Breaches, Client Money, Solicitors' Accounts Rules

    Fine, Strike off 1 PDF View decision
  • Mark Henry David Payne
    SDT solicitor 11908/2018 2018-01-01 found breached

    Breaches, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Joanne Power
    SDT solicitor 11779/2018 2018-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Maurice Frankson
    GLC attorney 68 of 2014 2017-12-19 found breached

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered December 19, 2017. || RESULT: Fined | Disciplinary Committee decision delivered January 4, 2018. View PDF DECISION OF THE DISCIPLINARY COMMIT…

    Guilty of Professional Misconduct 2 PDFs View decision
  • Howard A. Lettman
    GLC attorney 62 of 2110 2017-11-25 found breached

    Suspended | Disciplinary Committee decision delivered November 25, 2017. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO: 62/2110 IN THE MATTER OF RUDOLF CAMPBELL and HOWARD LET…

    Suspended 1 PDF View decision
  • Jermaine Ryan Simms
    GLC attorney 48 of 2009 2017-10-12 found breached

    Restitution Ordered | Disciplinary Committee decision delivered October 12, 2017. View PDF View Decision SANCTION DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO: 48/2009 IN THE MATTER O…

    Restitution Ordered 1 PDF View decision
  • Christopher Roy Penty
    LSBC lawyer 2017-09-28 found breached

    Agreed Statement of Facts | Summary

    Agreed Statement of Facts | Summary 1 PDF View decision
  • Berger, Victor
    OLSC solicitor Milne Berry & Berger [2017] NSWCATOD 137 2017-09-21 found breached

    1. Failure to make costs disclosure to clients 2. Breach undertakings to Legal Services Commissioner 3. Purporting to act under power of attorney after donor of power died 4. Purporting to act as exectuor when no grant …

    Costs Removal of lawyer's name from the Roll of Local Lawyers $0.00 Appeal Status: Dismissed Appeal Decision 3 PDFs View decision
  • Ivor George Peynado
    GLC attorney 41 of 2013 2017-06-24 found breached

    Guilty | Disciplinary Committee decision delivered June 24, 2017. || Suspended | Disciplinary Committee decision delivered April 17, 2019. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COM…

    Guilty 1 PDF View decision
  • Howard A. Lettman
    GLC attorney 29 of 2014 2017-06-24 found breached

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered June 24, 2017. || Struck off | Disciplinary Committee decision delivered February 05, 2018. View PDF DECISION OF THE DISCIPLINARY COMMITTEE O…

    Guilty of Professional Misconduct 1 PDF View decision
  • Peter Collins
    BTAS barrister Gray's Inn 2017-05-18 found breached
    strike_off Final 1 PDF View decision
  • Russell William Tracy BIDDLE
    LSC-QLD solicitor Biddle Lawyers 2017-04-27 found breached

    Professional misconduct (theft of a total of $1,821,230.59 from two of his clients' estates)

    other 1 PDF View decision
  • Jodi Leigh DINGWALL
    LSC-QLD solicitor Roverts Nehmer McKee 2017-03-21 found breached

    3 Charges of Delay and Failure to advance a client's actions - Proven. 3 Charges of False Representations - Proven.

    other 1 PDF View decision
  • Beazley, Philip James
    OLSC solicitor Beazley Boorman Lawyers [2017] NSWCATOD 35 2017-03-15 found breached

    Professional Misconduct: 1. Breach section 67 LPA 2004 - not notifying a show cause event 2. Failure to honour undertaking 3. Breach of section 254 LPA 2004 - failure to deposit trust money in a trust account 4. Breach …

    Costs Fine Reprimand $6,000.00 Proceedings Instituted 1 PDF View decision
  • Donnelly, Paul Joseph
    OLSC solicitor Donnelly Lawyers [2017] NSWCATOD 34 2017-03-14 found breached

    1. Failures to appear at Court 2. Breach of trust account obligations 3. Breach of costs disclosure obligations 4. Mixing of trust monies and office account monies 5. Misappropriation 6. Failure to respond to Regulator'…

    Costs Removal of practitioner's name from the Roll of Local Lawyers $0.00 Proceedings Instituted 1 PDF View decision
  • Chad Everett ROWE
    LSC-QLD solicitor Rowe Lawyers Pty Ltd 2017-03-10 found breached

    28 Charges of professional misconduct proven

    other 1 PDF View decision
  • David Herlihy
    LSI solicitor David Herlihy, Solicitors, Lord Edward Street, Kilmallock, Co Limerick 2017-03-10 found breached

    In the matter of David Herlihy, solicitor, formerly practising as principal of David Herlihy, Solicitors, Lord Edward Street, Kilmallock, Co Limerick, and in the matter of the Solicitors Acts 1954-2011 [9286/DT90/15 and…

    strike_off View decision
  • Harold C. Brady
    GLC attorney 78 of 2015 2017-02-25 found breached

    Finding of Professional Misconduct | Disciplinary Committee decision delivered February 25, 2017. | Struck off, Restitution ordered - March 4, 2017 View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL CO…

    Finding of Professional Misconduct 1 PDF View decision
  • John Gerard O'Donnell
    SSDT solicitor John Gerard O’Donnell, formerly of 14 Winton Drive, Glasgow and now residing at Flat 1/2, 322 Kelvindale Road, Glasgow 2017-02-15 found breached
    strike_off No Appeal 4 PDFs View decision
  • Patrick Stephen Alexander Copinger
    SSDT solicitor Patrick Stephen Alexander Copinger, Kirk House, 33 Miller Avenue, Wick, Caithness 2017-01-13 found breached
    dismissed Appeal Concluded 1 PDF View decision

Duty classification does not yet cover every jurisdiction (Ontario, New Zealand and Singapore decisions are indexed but not yet duty-classified), so counts here understate those corpora.