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discipline 1 October 2026

The duty in context

No improper use of client money money

The lawyer must withdraw client money only for its proper purpose, must not overdraw a client's funds, and must not use the client account as a banking facility.

1,489 cases 67% strike-off avg suspension 21.4 mo avg fine 50,037 794 with dishonesty finding

How the codes express this duty

E&W Solicitors SRA Principles & Code SAR Rule 5.1; SAR Rule 3.3; SAR Rule 5.3 strong 1,008 cases
5.1 You only withdraw client money from a client account: (a) for the purpose for which it is being held; ... 3.3 You must not use a client account to provide banking facilities to clients or third parties. ... 5.3 You only withdraw client money from a client account if sufficient funds are held on behalf of that specific client or third party to make the payment.
E&W Barristers BSB Handbook no clear equivalent
Cayman Islands Legal Services Code 2026 P.7; R.9.2 partial
Attorneys-at-law shall protect client money and assets... An attorney-at-law and a recognised law entity shall safeguard money and assets entrusted to them by clients and others.
AU Solicitors Solicitors' Conduct Rules no clear equivalent
AU Barristers Uniform Barristers Rules no clear equivalent
IE Solicitors Law Society Guide Ch9 — Accounts regulations: General strong 90 cases
To use each client's money for that client's matter only, To use trust money only for the purpose of that trust... To establish and maintain proper accounting systems and proper internal control systems to ensure compliance with the regulations.
IE Barristers Bar Code of Conduct no clear equivalent
JM Attorneys Canons of Professional Ethics Canon VII(a) partial 118 cases
An Attorney shall comply with rules as may from time to time be prescribed by the General Legal Council relating to the keeping in separate accounts- (i) the funds of himself or any firm with which he is associated; and (ii) those of his clients.
JE Lawyers Law Society of Jersey Code P.7; R.7.4 a),c) partial
Members must protect client money and assets... Members must: a) identify, monitor and manage risks to money and assets entrusted to them by clients and others... c) ensure compliance with the Accounts Rules.
ON Lawyers LSO Rules of Prof. Conduct r 3.6-10; r 3.2-7.3 strong
3.6-10 A lawyer shall not appropriate any funds of the client held in trust or otherwise under the lawyer's control for or on account of fees except as permitted by the by-laws under the Law Society Act. [3.2-7.3 A lawyer shall not use their trust account for purposes not related to the provision of legal services.]
BC Lawyers BC Code r 3.6-10 strong 71 cases
A lawyer must not appropriate any client funds held in trust or otherwise under the lawyer's control for or on account of fees, except as permitted by the governing legislation.
NZ Lawyers Conduct & Client Care Rules r 10.5.2 / r 9.3 partial
A lawyer who receives funds on terms requiring the lawyer to hold the funds in a trust account as a stakeholder must adhere strictly to those terms and disburse the funds only in accordance with them. ... A lawyer who wishes to debit fees held in trust or to receive funds to cover fees in advance must comply with the requirements of regulations 9 and 10 of the Lawyers and Conveyancers Act (Trust Account) Regulations 2008.
SCO Solicitors LSS Standards of Conduct no clear equivalent
SG Lawyers Professional Conduct Rules 2015 r 16 (Client money) partial 19 cases
16 Client money
HK Solicitors Solicitors' Guide Principle 13.02 / Principle 4.02 Commentary 4 partial
A client account cheque must never be dishonoured. A solicitor must take care to ensure that any cheque for use in connection with his practice will be honoured upon presentation. ... Dishonour of a client account cheque will other than in exceptional circumstances indicate a breach of the Solicitors' Accounts Rules (Cap. 159 sub. leg. F). ... Under rule 9(2) of the Solicitors' Accounts Rules (Cap. 159 sub. leg. F), money received for or on account of an agreed fee which is paid by a client to his solicitor must be paid into an office account.
HK Barristers Bar Code of Conduct no clear equivalent

Cases dealing with this duty

Clear

1,489 decisions · link basis: found breached = a tribunal finding; rule cited = the mapped provision is cited in the decision; text match = high-precision text pattern

  • Malcolm Reginald Brown
    SDT solicitor 9707/2007 2007-01-01 found breached

    Breaches, Client Money, Failures, Others

    Strike off 1 PDF View decision
  • Patricia Fox
    SDT solicitor 9711/2007 2007-01-01 found breached

    Others

    S.43 Order (clerks) 1 PDF View decision
  • John Peter Joseph Corr
    SDT solicitor 9739/2007 2007-01-01 found breached

    Breaches, Client Money

    Strike off 1 PDF View decision
  • Harbinder Singh Sangha
    SDT solicitor 9424/2007 2007-01-01 found breached

    Breaches, Client Money, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Judith Ihekerenma Nwokoro
    SDT solicitor 9772/2007 2007-01-01 found breached

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

    Suspend - Indefinite 1 PDF View decision
  • Ellen Jayne Godsell
    SDT solicitor 9794/2007 2007-01-01 found breached text match

    Breaches, Client Money, Solicitors' Accounts Rules, Others

    Suspend - Indefinite 1 PDF View decision
  • P G Stonelake & 2 Others
    SDT solicitor 9824/2007 2007-01-01 found breached

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

    Reprimand, Strike off, Suspend - Fixed Period 1 PDF View decision
  • B J F Dunleavy & A M Ahmed
    SDT solicitor 9694/2007 2007-01-01 found breached

    Client Money, Failures, Solicitors' Accounts Rules, Others

    Strike off 1 PDF View decision
  • Julian Anthony Norton Heron
    SDT solicitor 9712/2007 2007-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Charles Edward Shaw Rothwell
    SDT solicitor 9686/2007 2007-01-01 found breached text match

    Client Money, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Christopher Andrew Dudzinski
    SDT solicitor 9812/2007 2007-01-01 found breached

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

    Strike off 1 PDF View decision
  • G Okri & Another
    SDT solicitor 9736/2007 2007-01-01 found breached

    Breaches, Failures, Others

    Strike off, Suspend - Fixed Period 1 PDF View decision
  • B O Okafor & O L Ohre-Emuobosa
    SDT solicitor 9676/2007 2007-01-01 found breached

    Client Money, Failures, Solicitors' Accounts Rules

    Strike off, Suspend - Fixed Period 1 PDF View decision
  • Mubeen Kashmiri & Mahendra Chandmal Jain
    SDT solicitor 9657/2007 2007-01-01 found breached text match

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

    Strike off, Suspend - Indefinite 1 PDF View decision
  • J Kowalik
    SDT solicitor 9789/2007 2007-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules, Others

    Strike off 1 PDF View decision
  • Shannon Michelle Barber
    LSBC lawyer 2006-11-09 found breached

    Agreed Statement of Facts

    Agreed Statement of Facts View decision
  • Michael Lee PODMORE
    LSC-QLD solicitor Michael Podmore & Associates 2006-10-25 found breached

    Guilty of professional misconduct on 10 charges

    other 2 PDFs View decision
  • Cynthia D. Levy Brown
    GLC attorney 213 of 2004 2006-10-07 found breached

    Struck off, Restitution Ordered | Disciplinary Committee decision delivered October 07, 2006. View PDF DECISION of THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCILCOMPLAINT NO. 213/2004 In the Matter of Uriah & I…

    Struck off, Restitution Ordered 1 PDF View decision
  • VIJITHA GAMINI DE ALWIS
    LPBWA lawyer Suite 3, 1st Floor 544 Hay Street PERTH WA 6000 Legal Practitioners Complaints Committee v De Alwis [2006] WASCA 198 2006-09-29 found breached

    Struck Off the Roll of Practitioners

    Struck Off the Roll of Practitioners 1 PDF View decision
  • JANET WALTON
    LPBWA lawyer PO Box 45 OSBORNE PARK WA 6917 Legal Practitioners Complaints Committee v Walton [2006] WASC 213 2006-09-01 found breached

    Struck Off the Roll of Practitioners

    Struck Off the Roll of Practitioners 1 PDF View decision
  • David Kok Kwong Tsang
    LSBC lawyer 2006-07-13 found breached

    Agreed Statement of Facts

    Agreed Statement of Facts View decision
  • John William TOWERS
    LSC-QLD solicitor Coyne Coyne and Towers 2006-05-22 found breached

    Guilty of professional misconduct on 2 charges. Guilty of unsatisfactory professional conduct on 9 charges.

    other 1 PDF View decision
  • Lorraine Earle
    GLC attorney 87 of 2003 2006-05-13 found breached

    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
  • Pitsikas, Spero
    OLSC solicitor S Pitsikas & Associates [2006] NSWADT 102 2006-04-07 found breached

    1. Failure to account for trust money in breach of Section 61 of the Legal Profession Act 1987 2. Failure to keep proper trust records in breach of Section 62 of the Legal Profession Act 1987 3. Wilful breaches of trust…

    Costs Removal of practitioner's name from the Roll of Local Lawyers $0.00 Proceedings Instituted 1 PDF View decision
  • Audley Horatio Foster
    GLC attorney 164 of 2002 2006-04-01 found breached

    Restitution Ordered, Already Struck off | Disciplinary Committee decision delivered April 01, 2006. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCILCOMPLAINT N0. 164/2002 BETWEEN JANET ANDERS…

    Restitution Ordered, Already 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.