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discipline 1 October 2026

The duty in context

Manage conflict arising mid-matter client

Where a conflict arises after acting begins, the lawyer may continue for only one client (or a non-conflicting group) and only where confidentiality to the others is not put at risk.

23 cases 39% strike-off avg suspension 36.0 mo avg fine 6,000 4 with dishonesty finding

How the codes express this duty

E&W Solicitors SRA Principles & Code CCS 6.2 partial 8 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: ...
E&W Barristers BSB Handbook rC25; gC37 partial
rC25 Where you have accepted instructions to act but one or more of the circumstances set out in Rules rC21.1 to rC21.10 above then arises, you must cease to act and return your instructions promptly.
Cayman Islands Legal Services Code 2026 R.7.5 strong
if an attorney-at-law or a recognised law entity acts for more than one client in a matter and, during the course of the conduct of that matter, a conflict arises between the interests of two or more of those clients, the attorney-at-law or the recognised law entity may only continue to act for one of the clients (or a group of clients between whom there is no such conflict), and provided that the duty of confidentiality to the other client(s) is not put at risk
AU Solicitors Solicitors' Conduct Rules Rule 11.5 strong 1 case
If a solicitor or a law practice acts for more than one client in a matter and, during the course of the conduct of that matter, an actual conflict arises between the duties owed to two or more of those clients, the solicitor or law practice may only continue to act for one of those clients... in the following exceptional circumstances: 11.5.1 any client for whom the solicitor or law practice ceases to act has given informed consent...; and 11.5.2 the duty of confidentiality owed to all of the clients... is not put at risk.
AU Barristers Uniform Barristers Rules rr112-113 strong
A barrister must return a brief other than a brief to appear as soon as possible after the barrister becomes aware that the barrister has information confidential to a person other than the client which may, as a real possibility, be material to the client's case ... A barrister who is briefed to appear for two or more parties ... must then return the brief for ... one or more of the clients so as to remove that possibility of conflict.
IE Solicitors Law Society Guide Ch3 — Conflict of interest between solicitor and client partial
If the conflict arises during a transaction, the solicitor should give careful consideration to their position.
IE Barristers Bar Code of Conduct Rule 3.11 partial
and where they have accepted such instructions they should not continue to act.
JM Attorneys Canons of Professional Ethics Canon IV(k); Canon IV(m); Canon IV(n)(v) partial 13 cases
(k) ... 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 ... (m) In all situations where a possible conflict of interest arises, an Attorney shall resolve all doubts against the propriety of multiple representation. ... [An Attorney may at any time withdraw from employment:-] (v) where any of the provisions of Canon IV (j), (k) or (m) apply.
JE Lawyers Law Society of Jersey Code R.6.5 strong
if a member or their firm act for more than one client in a matter and, during the course of the conduct of that matter, a conflict arises between the interests of two or more of those clients, a member or their firm may only continue to act for one of the clients (or a group of clients between whom there is no such conflict), and provided that the duty of confidentiality to the other client(s) is not put at risk.
ON Lawyers LSO Rules of Prof. Conduct r 3.4-8 strong
Except as provided by rule 3.4-9, if a contentious issue arises between clients who have consented to a joint retainer, the lawyer shall not advise either of them on the contentious issue and the following rules apply: (a) The lawyer shall (i) refer the clients to other lawyers for that purpose; or (ii) if no legal advice is required and the clients are sophisticated, advise them that they have the option to settle the contentious issue by direct negotiation in which the lawyer does not participate. (b) If the contentious issue is not resolved, the lawyer shall withdraw from the joint representation.
BC Lawyers BC Code r 3.4-1 strong 1 case
A lawyer must not act or continue to act for a client where there is a conflict of interest, except as permitted under this Code.
NZ Lawyers Conduct & Client Care Rules r 6.1.2 / r 6.1.3 strong
Despite rule 6.1.1, if a lawyer is acting for more than 1 client in respect of a matter and it becomes apparent that the lawyer will no longer be able to discharge the obligations owed to all of the clients ..., the lawyer must immediately inform each of the clients ... Despite rule 6.1.2, a lawyer may continue to act for 1 client provided that the other clients ..., after receiving independent advice, give informed consent ...
SCO Solicitors LSS Standards of Conduct B1.7 partial
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) partial
20 Conflict, or potential conflict, between interests of 2 or more clients
HK Solicitors Solicitors' Guide Principle 9.04 / Commentary 4 strong
A solicitor or firm of solicitors must not continue to act for two or more joint clients when a conflict of interest arises between those joint clients. ... the solicitor must cease to act for both clients, unless he can without embarrassment and with propriety, continue to represent one client with the other's consent. A solicitor may only continue to represent one client where he is not in possession of relevant confidential information and knowledge concerning the other obtained whilst acting for the other.
HK Barristers Bar Code of Conduct para 6.10(c) strong
if having accepted instructions on behalf of more than one client there is or appears to be:- (i) a conflict or risk of conflict between the interests of any one or more of such clients; or (ii) a risk of a breach of confidence; and the clients do not all consent to him continuing to act for one or more of them or he is unable (even with the consent of all the clients) to continue to act for one or more of the clients without embarrassment;

Cases dealing with this duty

Clear

13 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 rule cited

    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
  • Trudy-Ann Francene G. Russell
    GLC attorney 35 of 2025 2026-02-07 rule cited

    Struck off | Disciplinary Committee decision delivered February 07, 2026. || Guilty of Professional Misconduct | Disciplinary Committee decision delivered January 17, 2026. View PDF SANCTION DECISION OF THE DISCIPLINARY…

    Struck off 2 PDFs View decision
  • Debby-Ann Samuels
    GLC attorney 35 of 2024 2025-12-12 rule cited

    Suspended | Disciplinary Committee decision delivered December 12, 2025. || Guilty of Professional Misconduct | Disciplinary Committee decision delivered April 14, 2025. View PDF SANCTION DECISION OF THE DISCIPLINARY CO…

    Suspended 2 PDFs View decision
  • Ano Maggielin Miller Sewell
    GLC attorney 117 of 2024 2025-06-27 rule cited

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

    Struck off, Restitution Ordered 2 PDFs View decision
  • Steven George Powell
    GLC attorney 176 of 2022 2025-05-13 rule cited

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

    Reprimanded 2 PDFs View decision
  • Michael Alexander Brown
    GLC attorney 117 of 2023 2025-05-13 rule cited

    Fined | Disciplinary Committee decision delivered May 13, 2025. || Guilty of Professional Misconduct | Disciplinary Committee decision delivered November 23, 2024. View PDF SANCTION DECISION OF THE DISCIPLINARY COMMITTE…

    Fined 2 PDFs View decision
  • Jennifer Jacqueline Housen
    GLC attorney 75 of 2021 2025-04-15 rule cited

    Suspended, Restitution Ordered | Disciplinary Committee decision delivered April 15, 2025. | Guilty of Professional Misconduct | Disciplinary Committee decision delivered April 25, 2024. View PDF DECISION ON SANCTION OF…

    Suspended, Restitution Ordered 2 PDFs View decision
  • Seymour George Stewart
    GLC attorney 78 of 2020 2021-07-26 rule cited

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered July 26, 2021. || Fined | Disciplinary Committee decision delivered November 03, 2021. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE…

    Guilty of Professional Misconduct 1 PDF View decision
  • Lawrence L. Haynes
    GLC attorney 140 of 2009 2013-05-04 rule cited

    Restitution ordered | Disciplinary Committee decision delivered May 04, 2013. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT No. 140/2009 IN THE MATTER of ROBERT HENRY and LAWRENC…

    Restitution ordered 1 PDF View decision
  • Lorraine Earle
    GLC attorney 87 of 2003 2006-05-13 rule cited

    Fined, Already Struck off | Disciplinary Committee decision delivered May 13, 2006. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THEGENERAL LEGAL COUNCILCOMPLAINT NO. 87/2003 In the Matter of LUNETH ORAM, RASFORD …

    Fined, Already Struck off 1 PDF View decision
  • Donald R. Bernard
    GLC attorney 45 of 2000 2003-02-22 rule cited

    Struck off | Disciplinary Committee decision delivered February 22, 2003. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL Complaint No. 45/2000 Hearing on the 9th day of February 2002 In the…

    Struck off 1 PDF View decision
  • Adrian A.F. “Freddie” Brown
    GLC attorney 123 of 1997 2001-08-10 rule cited

    Suspended | Disciplinary Committee decision delivered August 10, 2001. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCILCOMPLAINT No. 123/97 GUY AND LOIS HIBBERT COMPLAINANT AND FREDDIE BROWN …

    Suspended 1 PDF View decision
  • Enoch L. Blake
    GLC attorney 77 of 1991 1992-04-04 found breached

    Fined | Disciplinary Committee decision delivered April 04, 1992. View PDF DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL ORDER COMPLAINT NO. 77/91 In the matter of Spurgeon Reid and Enoch Blake Attorney-at-Law In …

    Fined 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.