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discipline 30 September 2026

The duty in context

Honour professional undertakings profession

The lawyer is personally bound to honour and perform within the agreed or a reasonable time any undertaking given, and must not give an undertaking they cannot fulfil or use one as an improper inducement.

450 cases 55% strike-off avg suspension 13.1 mo avg fine 77,603 105 with dishonesty finding

How the codes express this duty

E&W Solicitors SRA Principles & Code CCS 1.3 strong 224 cases
1.3 You perform all undertakings given by you, and do so within an agreed timescale or if no timescale has been agreed then within a reasonable amount of time.
E&W Barristers BSB Handbook rC11; gC33 partial 1 case
rC11 You must within an agreed timescale or within a reasonable period of time comply with any undertaking you give in the course of conducting litigation.
Cayman Islands Legal Services Code 2026 R.11.4 strong
An attorney-at-law who has given a personal undertaking to another attorney-at-law or a recognised law entity in the course of practice is personally bound by that undertaking, shall honour that undertaking and shall ensure that it is performed in a timely and effective manner, unless the attorney-at-law is clearly and unequivocally released by the recipient or the Court.
AU Solicitors Solicitors' Conduct Rules Rule 6.1 strong 92 cases
A solicitor who has given an undertaking in the course of legal practice must honour that undertaking and ensure the timely and effective performance of the undertaking, unless released by the recipient or by a court of competent jurisdiction.
AU Barristers Uniform Barristers Rules no clear equivalent
IE Solicitors Law Society Guide Ch6 — Undertakings: General; General guidance on undertakings strong 84 cases
A solicitor is required to honour the terms of an undertaking as a matter of professional conduct. A breach of an undertaking is a matter of professional misconduct... An undertaking should not be given by a solicitor as an inducement to a client to secure that client's business... A solicitor who gives an undertaking that is expressed to be dependent upon the happening of a future event should notify the recipient promptly if it becomes clear that the event will not occur.
IE Barristers Bar Code of Conduct no clear equivalent
JM Attorneys Canons of Professional Ethics Canon VI(c); Canon VI(d); Canon VI(e) strong 25 cases
(c) An Attorney shall not commit a breach of an undertaking given by him to a Judge, a Court or other tribunal or an official thereof ... (d) An Attorney shall not give a professional undertaking which he cannot fulfil and shall fulfil every such undertaking which he gives.
JE Lawyers Law Society of Jersey Code R.10.4 strong
A member who has given, or whose employee has given, an undertaking to another member or the firm of another member in the course of practice is personally bound by that undertaking and must honour that undertaking and ensure that it is performed in a timely and effective manner.
ON Lawyers LSO Rules of Prof. Conduct r 7.2-11; r 5.1-6 strong
7.2-11 A lawyer shall not give an undertaking that cannot be fulfilled and shall fulfill every undertaking given and honour every trust condition once accepted. [5.1-6: A lawyer must strictly and scrupulously fulfill any undertakings given by him or her and honour any trust conditions accepted in the course of litigation.]
BC Lawyers BC Code r 7.2-11 strong 7 cases
A lawyer must: (a) not give an undertaking that cannot be fulfilled; (b) fulfill every undertaking given; and (c) honour every trust condition once accepted.
NZ Lawyers Conduct & Client Care Rules r 10.5 strong
A lawyer must honour all undertakings, whether written or oral, that the lawyer gives to any person in the course of practice.
SCO Solicitors LSS Standards of Conduct B1.14 partial 8 cases
You must act with other regulated persons in a manner consistent with persons having mutual trust and confidence in each other.
SG Lawyers Professional Conduct Rules 2015 r 7 (Responsibilities of legal practitioners to each other) partial 6 cases
7 Responsibilities of legal practitioners to each other
HK Solicitors Solicitors' Guide Principle 14.02 / Principle 14.01 strong
A solicitor must honour the terms of a professional undertaking. ... An undertaking shall only be given by a solicitor and is binding upon him personally, and if given in the course of practice, also binds his firm. ... an undertaking should never be given unless the solicitor giving it is certain that he personally can comply with it.
HK Barristers Bar Code of Conduct para 10.4 strong
A practising barrister, while engaging in practice, must not give any undertaking that cannot be fulfilled and must fulfil every undertaking that has been given by him.

Cases dealing with this duty

Clear

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

  • Antoneita Alicia Hall
    GLC attorney 177 of 2024 2026-02-28 found breached text match

    Suspended | Disciplinary Committee decision delivered February 28, 2026. || Guilty of Misconduct in a Professional Respect | Disciplinary Committee decision delivered November 22, 2025. View PDF SANCTION DECISION OF THE…

    Suspended 2 PDFs View decision
  • Antoneita Alicia Hall
    GLC attorney 177 of 2024 2025-11-22 text match

    Guilty of Misconduct in a Professional Respect | Disciplinary Committee decision delivered November 22, 2025. || Suspended | Disciplinary Committee decision delivered February 28, 2026. View PDF DECISION OF THE DISCIPLI…

    Guilty of Misconduct in a Professional Respect 1 PDF View decision
  • Ano Maggielin Miller Sewell
    GLC attorney 117 of 2024 2025-05-31 rule cited

    Guilty | Disciplinary Committee decision delivered May 31, 2025. || Struck off, Restitution Ordered | Disciplinary Committee decision delivered June 27, 2025. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENER…

    Guilty 1 PDF View decision
  • Steven George Powell
    GLC attorney 176 of 2022 2024-11-28 rule cited

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered November 28, 2024. || Disciplinary Committee decision delivered May 13, 2025. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL …

    Guilty of Professional Misconduct 1 PDF View decision
  • Barbara Ledgister
    GLC attorney 111 of 2019 2023-12-06 rule cited

    Suspended | Disciplinary Committee decision delivered December 06, 2023 | Guilty of Professional Misconduct | Disciplinary Committee decision delivered June 16, 2020. View PDF DECISION ON SANCTION OF THE DISCIPLINARY CO…

    Suspended 2 PDFs View decision
  • Tanya Latoya Walters Powell
    GLC attorney 176 of 2018 2021-12-03 rule cited

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered December 3, 2021. ||Restitution ordered, Fined | Disciplinary Committee decision delivered March 09, 2022 View PDF DECISION OF THE DISCIPLINA…

    Guilty of Professional Misconduct 4 PDFs View decision
  • Lancelot A. St. Martin Cowan
    GLC attorney 39 of 2019 2021-07-10 rule cited

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered July 10, 2021. || RESULT: Restitution ordered | Disciplinary Committee decision delivered October 23, 2021. View PDF in Full Screen …

    Guilty of Professional Misconduct 1 PDF View decision
  • W. Anthony Pearson
    GLC attorney 18 of 2018 2021-04-24 text match

    Guilty of Misconduct in a Professional Respect | Disciplinary Committee decision delivered April 24, 2021. || Fined | Disciplinary Committee decision delivered June 04, 2021. View PDF in Full Screen Back to top …

    Guilty of Misconduct in a Professional Respect 1 PDF View decision
  • Arlean D. Moreta Beckford
    GLC attorney 135 of 2013 2021-01-26 found breached

    Struck off, Restitution Ordered | Disciplinary Committee decision delivered January 26, 2021. || Guilty of Professional Misconduct | Disciplinary Committee decision delivered January 13, 2021. View PDF DECISION ON SANCT…

    Struck off, Restitution Ordered 1 PDF View decision
  • Graceann Marie Cameron
    GLC attorney 38 of 2015 2020-12-12 found breached

    Struck off, Restitution Ordered | Disciplinary Committee decision delivered December 12, 2020. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO: 38/2015 IN THE MATTER OF MELISA J…

    Struck off, Restitution Ordered 1 PDF View decision
  • Barbara Ledgister
    GLC attorney 111 of 2019 2020-06-16 rule cited

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered June 16, 2020 | Suspended | Disciplinary Committee decision delivered December 06, 2023. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF T…

    Guilty of Professional Misconduct 2 PDFs View decision
  • Raymond Clough
    GLC attorney 186 of 2010 2019-07-26 text match

    Suspended, Fined - Disciplinary Committee decision delivered July 26, 2019. | Guilty of Professional Misconduct - Disciplinary Committee decision May 11, 2019. | Formal Order July 26, 2019 View PDF DECISION OF THE DISCI…

    Suspended, Fined - Disciplinary Committee decision delivered July 26, 2019. 1 PDF View decision
  • Jerome Alexander Dixon
    GLC attorney 255 of 2017 2018-10-27 found breached

    Struck off | Disciplinary Committee decision delivered October 27, 2018. || RESULT: Guilty of Professional Misconduct | Disciplinary Committee decision delivered October 01, 2018. View PDF of Decision View PDF of Formal…

    Struck off 2 PDFs View decision
  • Jennifer Messado
    GLC attorney 124 of 2017 2018-10-08 text match

    Struck off | Disciplinary Committee decision delivered October 08, 2018 - Sanction Hearing. || Guilty of Professional Misconduct | Disciplinary Committee decision delivered September 15, 2018. View PDF DECISION OF THE D…

    Struck off 1 PDF View decision
  • Jerome Alexander Dixon
    GLC attorney 255 of 2017 2018-10-01 found breached rule cited

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered October 01, 2018. || RESULT: Struck off | Disciplinary Committee decision delivered October 27, 2018. View PDF DECISION OF THE DISCIPLINARY C…

    Guilty of Professional Misconduct 1 PDF View decision
  • Lancelot A. St. Martin Cowan
    GLC attorney 17 of 2016 2018-09-20 text match

    Struck off | Disciplinary Committee decision delivered September 20, 2018. || RESULT: Guilty of Professional Misconduct | Disciplinary Committee decision delivered March 14, 2018. View PDF DECISION ON SANCTION IN THE MA…

    Struck off 1 PDF View decision
  • Jennifer Messado
    GLC attorney 124 of 2017 2018-09-15 rule cited

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered September 15, 2018. || Struck off | Disciplinary Committee decision delivered October 08, 2018 - Sanction Hearing. View PDF DECISION OF THE D…

    Guilty of Professional Misconduct 1 PDF View decision
  • Leighton O. Miller
    GLC attorney 5 of 2010 2014-03-22 rule cited

    Suspended, Restitution Ordered | Disciplinary Committee decision delivered March 22, 2014. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO: 5/2010 BETWEEN RICARDO BOND COMPLAINA…

    Suspended, Restitution Ordered 1 PDF View decision
  • Debayo Adedipe
    GLC attorney 82 of 2010 2011-10-21 found breached

    Payment ordered | Disciplinary Committee decision delivered October 21, 2011. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO: 82/2010 BETWEEN CHERRIL LAM & FITZROY McLEISH COMP…

    Payment ordered 1 PDF View decision
  • Jermaine Ryan Simms
    GLC attorney 41 of 2009 2011-02-19 found breached rule cited

    Struck off, Restitution Ordered | Disciplinary Committee decision delivered February 19, 2011. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCILCOMPLAINT No. 41/2009 BETWEEN MARINE WILDLIFE PU…

    Struck off, Restitution Ordered 1 PDF View decision
  • Michael A. Williams
    GLC attorney 242 of 2005 2008-12-13 rule cited

    Restitution Ordered, Fined | Disciplinary Committee decision delivered December 13, 2008. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT No. 242 OF 2005 IN THE MATTER OF A COMPLAI…

    Restitution Ordered, Fined 1 PDF View decision
  • Beriston Bryan
    GLC attorney 131 of 2003 2008-10-04 rule cited

    Fined, Restitution Ordered | Disciplinary Committee decision delivered October 04, 2008. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT No. 131 OF 2003 IN THE MATTER OF A COMPLAIN…

    Fined, Restitution Ordered 1 PDF View decision
  • Shaun A. Reynolds
    GLC attorney 43 of 1997 2001-04-21 found breached rule cited

    Suspended, Repayment ordered | Disciplinary Committee decision delivered April 21, 2001. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO. 43/97 FREDERICK O’MEALLY COMPLAINANT AN…

    Suspended, Repayment ordered 1 PDF View decision
  • Franklyn S. Beckford
    GLC attorney 166 of 1992 1999-09-15 rule cited

    Suspended, Withdrawn | Disciplinary Committee decision delivered September 15, 1999. View PDF FORMAL ORDER OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL MADE ON COMPLAINTNo. 166 of 1992 IN THE MATTER of SAR…

    Suspended, Withdrawn 1 PDF View decision
  • Pauline Simpson
    GLC attorney 6 of 1993 1993-10-19 found breached text match

    Struck off | Disciplinary Committee decision delivered October 19, 1993. View PDF GORDON BROWN VS PAULINE SIMPSON COMPLAINT NO. 6/93 DECISION This complaint was brought by Mr. Gordon Brown of the firm Perkins, Grant, St…

    Struck off 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.