Janice A. Causwell

Findings — machine-extracted (anthropic-batch:claude-opus-4-8); verify against the decision

Appeal to the Privy Council from the Court of Appeal of Jamaica concerning a point of law under the Legal Profession Act: whether disciplinary proceedings initiated by a purported agent (Mrs Hartley) without the complainant's (Mr DeCordova's) authority could be cured by subsequent ratification. The underlying complaint against attorney Janice Causwell alleged failure to deal with an estate matter expeditiously, failure to provide progress information, and inexcusable/deplorable negligence, but these allegations were never determined on the merits. The Disciplinary Committee had found Mrs Hartley lacked initial authority but that Mr DeCordova ratified her actions by letters in 2004. The Court of Appeal held the unauthorised initiation was a nullity incapable of ratification. The Board disagreed, holding that under ordinary agency principles ratification is permitted absent contrary statutory intention, and nothing in section 12 LPA prohibited ratification. The Board allowed the appeal and reinstated the Committee's decision, allowing the complaint to proceed. No finding of dishonesty was made; no sanction or financial order against the attorney was made.