Skip to main content
discipline 30 September 2026

The duty in context

Advise objectively, not a mere conduit client

The lawyer must exercise independent forensic and professional judgment for the client's benefit and must not act as a mere mouthpiece or conduit for the client's instructions.

387 cases 68% strike-off avg suspension 12.0 mo avg fine 255,000 6 with dishonesty finding

How the codes express this duty

E&W Solicitors SRA Principles & Code Principle 3; Principle 7 partial 363 cases
You act: 1.3 with independence. 1.7 in the best interests of each client.
E&W Barristers BSB Handbook rC20; CD4 strong 4 cases
rC20 Where you are a BSB authorised individual, you are personally responsible for your own conduct and for your professional work. You must use your own professional judgment in relation to those matters on which you are instructed and be able to justify your decisions and actions. You must do this notwithstanding the views of your client, professional client, employer or any other person.
Cayman Islands Legal Services Code 2026 R.6.1(b); P.5 partial
not permit a professional client, a recognised law entity or any other person to limit the attorney-at-law's discretion as to how the interests of the client can best be served
AU Solicitors Solicitors' Conduct Rules Rule 17.1 strong 9 cases
A solicitor representing a client in a matter that is before the court must not act as the mere mouthpiece of the client or of the instructing solicitor (if any) and must exercise the forensic judgments called for during the case independently, after the appropriate consideration of the client's and the instructing solicitor's instructions where applicable.
AU Barristers Uniform Barristers Rules r41 strong 4 cases
A barrister must not act as the mere mouthpiece of the client or of the instructing solicitor and must exercise the forensic judgments called for during the case independently, after the appropriate consideration of the client's and the instructing solicitor's wishes where practicable.
IE Solicitors Law Society Guide Ch1 — The function of the solicitor in society; Ch6 — Litigation: initiating letters and correspondence strong 1 case
Barron J set out the obligation of the solicitor in Doran v Delaney... as follows: "The solicitor is not a conduit pipe."... A solicitor is not a mere conduit for their client's instructions and should not purport to represent their clients' instructions as facts.
IE Barristers Bar Code of Conduct Rule 5.15 strong 1 case
A barrister when conducting proceedings in Court is responsible for the conduct and presentation of his case, and must exercise the independent judgment called for during the case. A barrister must not act as a mere spokesperson for the client or the instructing solicitor.
JM Attorneys Canons of Professional Ethics Canon IV(c) strong 3 cases
An Attorney shall exercise independent judgment within the bounds of the law and the ethics of the profession for the benefit of his client.
JE Lawyers Law Society of Jersey Code R.5.1 d); P.5 strong
Members must: ... d) not permit their professional client, firm or any other person to limit their discretion as to how the interests of the client can best be served.
ON Lawyers LSO Rules of Prof. Conduct r 3.2-2 commentary [2] strong
The lawyer's duty to the client who seeks legal advice is to give the client a competent opinion based on a sufficient knowledge of the relevant facts, an adequate consideration of the applicable law, and the lawyer's own experience and expertise. The advice must be open and undisguised and must clearly disclose what the lawyer honestly thinks about the merits and probable results.
BC Lawyers BC Code r 2.1-3(a) strong 4 cases
A lawyer should obtain sufficient knowledge of the relevant facts and give adequate consideration to the applicable law before advising a client, and give an open and undisguised opinion of the merits and probable results of the client's cause. The lawyer should be wary of bold and confident assurances to the client, especially where the lawyer's employment may depend on such assurances.
NZ Lawyers Conduct & Client Care Rules r 5.3 strong
A lawyer must at all times exercise independent professional judgement on a client's behalf. A lawyer must give objective advice to the client based on the lawyer's understanding of the law.
SCO Solicitors LSS Standards of Conduct B1.3 partial
You must give independent advice free from external influences or personal interests which are inconsistent with these standards.
SG Lawyers Professional Conduct Rules 2015 no clear equivalent
HK Solicitors Solicitors' Guide Principle 5.18 / Principle 5.19 strong
A solicitor must be both honest and candid when advising a client and give objective advice. ... A solicitor's advice must be unbiased and not be influenced by whether his employment or other work may depend upon advising in a particular way.
HK Barristers Bar Code of Conduct para 10.17(a) strong
A practising barrister must, however, not act as the mere mouthpiece of the client or the instructing person and must exercise the professional judgments called for during the case independently, after appropriate consideration of the client's and the instructing person's wishes where practicable.

Cases dealing with this duty

Clear

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

  • Mohamed Faisal Mamon
    SDT solicitor 12831/2025 2026-05-19 rule cited

    Breaches, Code of Conduct for Solicitors, REL's & RFL's 2019, Indemnity Insurance Rules, Recklessness, SRA Principles 2019

    Suspend - Fixed Period 1 PDF View decision
  • Vipul Kapoor
    SDT solicitor 12793/2025 2026-05-12 rule cited

    Breaches, Code of Conduct 2011, Code of Conduct for Solicitors, REL's & RFL's 2019, SRA Principles 2011, SRA Principles 2019

    Fine 1 PDF View decision
  • Anthony Burns
    SDT solicitor 12677/2024 2026-05-06 rule cited

    Breaches, Code of Conduct 2011, Code of Conduct for Solicitors, REL's & RFL's 2019, SRA Principles 2011, SRA Principles 2019

    Strike off 1 PDF View decision
  • Maame Adjoa Djan-Krofa
    SDT solicitor 12771/2025 2026-04-30 rule cited

    Breaches, Code of Conduct for Solicitors, REL's & RFL's 2019, SRA Principles 2019

    Suspended period of Suspension 1 PDF View decision
  • Alexander William Bruce Lee
    SDT solicitor 12813/2025 2026-04-28 rule cited

    Breaches, Code of Conduct 2011, SRA Principles 2011

    Fine 1 PDF View decision
  • Nicholas Devlin
    SDT solicitor 12862/2025 2026-04-20 rule cited

    Breaches, Code of Conduct for Solicitors, REL's & RFL's 2019, Dishonesty, Solicitors Accounts Rules 2019

    Strike off 1 PDF View decision
  • Christopher Yiannakas; Nicholas George Kephalas; YVA Solicitors LLP
    SDT solicitor 12728/2025 2026-03-30 rule cited

    Code of Conduct for Firms 2019, Solicitors Accounts Rules 2019, SRA Principles 2019

    Fine 1 PDF View decision
  • Darren Hanison
    SDT solicitor 12764/2025 2026-03-19 rule cited

    Breaches, Code of Conduct 2011, Code of Conduct for Solicitors, REL's & RFL's 2019, Dishonesty, Solicitors Accounts Rules 2019, SRA Principles 2011, SRA Principles 2019

    Strike off 1 PDF View decision
  • Gboyega Ajibola Okunniga
    SDT solicitor 12754/2025 2026-03-19 rule cited

    Breaches, Code of Conduct for Solicitors, REL's & RFL's 2019, SRA Principles 2011, SRA Principles 2019

    Strike off 1 PDF View decision
  • Shafiq-ul Hassan
    SDT solicitor 12567/2024 2026-03-12 rule cited

    Breaches, Code of Conduct 2011, Code of Conduct for Solicitors, REL's & RFL's 2019, SRA Principles 2011, SRA Principles 2019

    Suspend - Fixed Period 1 PDF View decision
  • Claire Frances Gill
    SDT solicitor 12775/2025 2026-03-09 rule cited
    Proceedings Dismissed 1 PDF View decision
  • Michelle Niaz
    SDT solicitor 12767/2025 2026-02-17 rule cited

    Authorisation of Individuals Regulations 2019, Client Money, Code of Conduct for Solicitors, REL's & RFL's 2019, Solicitors Accounts Rules 2011, Solicitors Accounts Rules 2019, SRA Principles 2011, SRA Principles 2019

    Suspend - Fixed Period 1 PDF View decision
  • David Buckle
    SDT solicitor 12615/2024 2026-01-26 rule cited

    Breaches, Code of Conduct 2011, Code of Conduct for Solicitors, REL's & RFL's 2019, SRA Principles 2011, SRA Principles 2019

    Not Proved/Dismissed 1 PDF View decision
  • Carter Devile
    SDT solicitor 12597/2024 2026-01-16 rule cited

    Breaches, Code of Conduct 2011, Code of Conduct for Firms 2019, Money Laundering Regulations, SRA Principles 2011

    Costs only, No Order 1 PDF View decision
  • Rehana Saeed
    SDT solicitor 12597/2024 2026-01-12 rule cited

    Breaches, Code of Conduct 2011, Money Laundering Regulations, SRA Principles 2011

    Fine 1 PDF View decision
  • Md Zahidul Islam; Zarina Shaheen Bostan; Nageena Choudhry; Mohammed Saleem
    SDT solicitor 12651/2024 2026-01-08 rule cited

    Code of Conduct for Firms 2019, Code of Conduct for Solicitors, REL's & RFL's 2019, Solicitors' Accounts Rules

    Fine, Not Proved/Dismissed 1 PDF View decision
  • Shahid Ali
    SDT solicitor 12685/2024 2026-01-06 rule cited

    Breaches, Client Money, Code of Conduct 2011, Code of Conduct for Solicitors, REL's & RFL's 2019, Dishonesty, Solicitors Accounts Rules 2011, Solicitors Accounts Rules 2019, SRA Principles 2011, SRA Principles 2019

    Fine 1 PDF View decision
  • Rohan Slater
    LSC-QLD solicitor 2025-12-19 rule cited

    Charge is proved and professional misconduct is established

    Suspended (01/02/2026 - 31/12/2026); Reprimand 1 PDF View decision
  • Paul Edmund Levy
    SDT solicitor 12739/2025 2025-12-02 rule cited

    Breaches, Code of Conduct 2011, SRA Principles 2011, SRA Principles 2019

    Fine 1 PDF View decision
  • Mohammed Israr
    SDT solicitor 12707/2024 2025-11-18 rule cited

    Code of Conduct for Solicitors, REL's & RFL's 2019, Recklessness, SRA Principles 2019

    Not Proved/Dismissed 1 PDF View decision
  • Stefanie Anne O’Bryen
    SDT solicitor 12611/2024 2025-11-03 rule cited

    Breaches, Code of Conduct for Firms 2019, Code of Conduct for Solicitors, REL's & RFL's 2019, Money Laundering Regulations, Solicitors Accounts Rules 2019

    Suspend - Fixed Period 1 PDF View decision
  • Charles Ogbonna Azotam
    SDT solicitor 12777/2025 2025-10-24 rule cited

    Client Money, Code of Conduct for Solicitors, REL's & RFL's 2019, Solicitors' Accounts Rules, SRA Principles 2019

    Strike off 1 PDF View decision
  • (unnamed)
    SDT solicitor 12755/2025 2025-10-21 rule cited
    Restoration to the Roll - Refused 1 PDF View decision
  • Paul Andrew Smith
    SDT solicitor 12732/2025 2025-10-09 rule cited

    Breaches, Code of Conduct for Solicitors, REL's & RFL's 2019, Dishonesty, Lack of Integrity, SRA Principles 2019

    Strike off 1 PDF View decision
  • Daniel Jones
    SDT solicitor 12603/2024 2025-10-09 rule cited

    Code of Conduct for Solicitors, REL's & RFL's 2019, Recklessness, SRA Principles 2019

    Fine 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.