Skip to main content
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

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

  • Brendan MacNamara
    LSI solicitor Devitt Doorley MacNamara, The Valley, Roscrea, Co Tipperary 2013-01-21 found breached

    In the matter of Brendan MacNamara, solicitor, formerly practising as a partner in the practice of Devitt Doorley MacNamara, The Valley, Roscrea, Co Tipperary, and in the matter of the Solicitors Acts 1954-2011 [10447/D…

    strike_off View decision
  • Brian Johnston
    LSI solicitor Brian Johnston & Co, Solicitors, 79 Park Street, Dundalk, Co Louth 2013-01-21 found breached text match

    In the matter of Brian Johnston, a solicitor formerly practising as Brian Johnston & Co, Solicitors, 79 Park Street, Dundalk, Co Louth and in the matter of the Solicitors Acts 1954-2008 [6927/DT65/10 and High Court reco…

    strike_off View decision
  • Dlakic, Amil
    OLSC solicitor Johnston Vaughan Solicitors & Attorneys 2013-01-18 text match

    Breach of undertaking given in court — A reasonable likelihood of a finding of unsatisfactory professional conduct

    Reprimand $0.00 About ​ About the OLSC The Commissioner History Mission statement Structure Contact ​ Contact the OLSC Give us your feedback: online surveys Access to information (GIPAA) Community information ​ Information for lawyers Fact sheets FAQs Other regulatory and complaint-handling organisations Contact LawAccess NSW for legal information " You and Your Lawyer", Hot ​​Topics 78 Legal Information Access Centre (LIAC), State Library of NSW​ , provides access to information about the law in NSW regarding your lawyer Privacy Copyright and Disclaimer Website accessibility View decision
  • Greg (otherwise John G) Casey
    LSI solicitor Casey & Co, Solicitors, at North Main Street, Bandon, Co Cork 2013-01-16 found breached text match

    In the matter of Greg (otherwise John G) Casey, formerly practising in the solicitors’ firm of Casey & Co, Solicitors, at North Main Street, Bandon, Co Cork, and in the matter of Mairead Casey, a solicitor formerly prac…

    strike_off View decision
  • Steven Ronald Shepherd
    SDT solicitor 11184/2013 2013-01-01 text match

    Criminal Convictions

    Strike off 1 PDF View decision
  • Walter Forbes Ruark
    SSDT solicitor Walter Forbes Ruark, Solicitor, 42 Ireland Street, Carnoustie 2012-11-15 found breached
    strike_off No Appeal 1 PDF View decision
  • MARK ANTHONY DETATA
    LPBWA lawyer P O Box 1079 WEST PERTH WA 6872 Legal Profession Complaints Committee v Detata [2012] WASCA 214 2012-10-26 found breached

    Order to pay fine

    Order to pay fine 1 PDF View decision
  • Jacqueline M Durcan
    LSI solicitor Durcans Solicitors, 1 Hazel Grove, Spencer Park, Castlebar, Co Mayo 2012-10-08 text match

    In the matter of Jacqueline M Durcan, solicitor, formerly practising as Durcans Solicitors, 1 Hazel Grove, Spencer Park, Castlebar, Co Mayo, and in the matter of the Solicitors Acts 1954-2008 [7083/DT86/11 and 2012 no 7…

    strike_off View decision
  • Mee Ling, Paul Adrian
    OLSC solicitor Mee Ling [2012] NSWADT 146 2012-07-25 found breached text match

    Application no. 102024: 1. Failure to comply with undertaking 2. Failure to comply with condition on practising certificate 3. Failure to respond to the Society’s correspondence Application no. 102025: 1. Failure to pay…

    Costs Removal of practitioner's name from the Roll of Local Lawyers $0.00 Proceedings Instituted View decision
  • Noel Brennan
    LSI solicitor Joy Brennan & Company, Solicitors, 1 New Quay, Clonmel, Co Tipperary 2012-07-23 found breached text match

    In the matter of Noel Brennan, a solicitor formerly practising as a partner in Joy Brennan & Company, Solicitors, at 1 New Quay, Clonmel, Co Tipperary, and in the matter of the Solicitors Acts 1954-2008 [4028/DT22/11 an…

  • Katherine MA Ryan
    LSI solicitor Ryan & Company, 42 Woodley Park, Kilmacud, Dublin 14 2012-03-26 text match

    In the matter of Katherine MA Ryan, a solicitor formerly practising under the style and title of Ryan & Company, Solicitors, at 42 Woodley Park, Kilmacud, Dublin 14, and in the matter of the Solicitors Acts 1954-2008 [6…

    strike_off View decision
  • Katherine MA Ryan
    LSI solicitor Ryan & Company, 42 Woodley Park, Kilmacud, Dublin 14 2012-03-26 text match

    In the matter of Katherine MA Ryan, a solicitor formerly practising under the style and title of Ryan & Company at 42 Woodley Park, Kilmacud, Dublin 14, and in the matter of the Solicitors Acts 1954-2008 [6970/DT35/10; …

    strike_off View decision
  • Kim, Jinhi
    OLSC solicitor (Formerly) Temple Lawyers Pty Ltd [2012] NSWADT 45 2012-03-20 text match

    1. Practice in breach of condition in Practising Certificate 2. Breach of undertaking to Law Society of NSW 3. Failure to respond to correspondence from the Law Society of NSW — Professional Misconduct

    Additional Orders made by the Tribunal (see Tribunal decision) Costs Fine Reprimand $5,000.00 Proceedings Instituted View decision
  • Jacqueline M Durcan
    LSI solicitor Durcans Solicitors, 1 Hazel Grove, Spencer Park, Castlebar, Co Mayo 2012-02-13 found breached text match

    In the matter of Jacqueline M Durcan, solicitor, formerly practising as Durcans Solicitors, no 1 Hazel Grove, Spencer Park, Castlebar, Co Mayo, and in the matter of the Solicitors Acts 1954-2011 [7083/DT46/11 and 2012 n…

    strike_off View decision
  • Boon Low
    SDT solicitor 10913/2012 2012-01-01 found breached text match

    Breaches, Failures

    Strike off 1 PDF View decision
  • Eshrat Saddiq
    SDT solicitor 11050/2012 2012-01-01 found breached

    Others

    S.43 Order (clerks) 1 PDF View decision
  • Anwaar Ul Haq & Sridevi Veldandi
    SDT solicitor 10925/2012 2012-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off, Strike Off Register of Foreign Lawyers 1 PDF View decision
  • Hatch - Clerey - Macdonald
    SDT solicitor 11016/2012 2012-01-01 found breached text match

    Failures, Others

    Strike off 1 PDF View decision
  • Issac Agyemang Baffour
    SDT solicitor 11042/2012 2012-01-01 found breached text match

    Breaches, Failures, Others

    Strike off 1 PDF View decision
  • Simon William Griffiths
    SDT solicitor 11100/2012 2012-01-01 found breached text match

    Breaches, Client Money, Failures, Others, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Miles Roderick Cox & Another
    SDT solicitor 10946/2012 2012-01-01 text match

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Fine, Strike off 1 PDF View decision
  • Charles Elwes Dunbar
    SDT solicitor 11055/2012 2012-01-01 found breached text match

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Anthony Robert Bogan
    SDT solicitor 10973/2012 2012-01-01 found breached

    Breaches, Others

    Strike off 1 PDF View decision
  • Gallagher, Patrick James
    OLSC solicitor AON Global Risk Consulting 2011-11-03 text match

    1. Cntravened a condition of his practising certificate. 2. Failed to comply with his undertaking of 9 February 2009 to the Law Society of New South Wales. — A reasonable likelihood of a finding of unsatisfactory profes…

    Reprimand $0.00 About ​ About the OLSC The Commissioner History Mission statement Structure Contact ​ Contact the OLSC Give us your feedback: online surveys Access to information (GIPAA) Community information ​ Information for lawyers Fact sheets FAQs Other regulatory and complaint-handling organisations Contact LawAccess NSW for legal information " You and Your Lawyer", Hot ​​Topics 78 Legal Information Access Centre (LIAC), State Library of NSW​ , provides access to information about the law in NSW regarding your lawyer Privacy Copyright and Disclaimer Website accessibility View decision
  • Jiang, Ren Hai
    OLSC solicitor Churchill Lawyers [2011] NSWADT 270 2011-10-28 found breached text match

    1. Breach of undertaking 2. Misled the Vendor's Solicitor 3. Failed to render to his employer trust monies received from clients of the law practice and deposited these monies to his own account 4. Practised in contrave…

    Additional Orders made by the Tribunal (see Tribunal decision) Fine Impose conditions on Practising Certificate Reprimand $9,000.00 Proceedings Instituted 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.