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discipline 4 October 2026

The duty in context

No baseless or threatened misconduct report profession

The lawyer must not make or threaten a professional-misconduct allegation or report without a genuine, reasonably held and bona fide belief that it applies.

505 cases 43% strike-off avg suspension 15.0 mo avg fine 83,213 198 with dishonesty finding

How the codes express this duty

E&W Solicitors SRA Principles & Code no clear equivalent
E&W Barristers BSB Handbook rC67 strong 28 cases
rC67 You must never make, or threaten to make, a report under Rule rC66 without a genuine and reasonably held belief that Rule rC66 applies.

BSB Handbook Part 2: Code of Conduct · 5.0 · archived copy · official source ↗

Cayman Islands Legal Services Code 2026 no clear equivalent
AU Solicitors Solicitors' Conduct Rules Rule 32.1 strong 198 cases
A solicitor must not make an allegation against another Australian legal practitioner of unsatisfactory professional conduct or professional misconduct unless the allegation is made bona fide and the solicitor believes on reasonable grounds that available material by which the allegation could be supported provides a proper basis for it.

Australian Solicitors' Conduct Rules · 2015 (June 2026 compilation) · archived copy · official source ↗

AU Barristers Uniform Barristers Rules no clear equivalent
IE Solicitors Law Society Guide no clear equivalent
IE Barristers Bar Code of Conduct no clear equivalent
JM Attorneys Canons of Professional Ethics no clear equivalent
JE Lawyers Law Society of Jersey Code no clear equivalent
ON Lawyers LSO Rules of Prof. Conduct r 3.2-5(b); r 7.1-3 commentary [1] partial
3.2-5 A lawyer shall not, in an attempt to gain a benefit for a client, threaten, or advise a client to threaten, without reasonable and lawful justification ... (b) to make a complaint to a regulatory authority. [7.1-3 commentary [1]: In all cases, the report must be made without malice or ulterior motive. 3.2-5 commentary [1]: It is an abuse of the process of a court or, ordinarily, a regulatory authority to threaten to make or advance a charge or complaint in order to secure the satisfaction of a private grievance.]

Law Society of Ontario — Rules of Professional Conduct · current · archived copy · official source ↗

BC Lawyers BC Code r 7.1-3, commentary [2] partial 37 cases
Nothing in this paragraph is meant to interfere with the lawyer-client relationship. In all cases, the report must be made without malice or ulterior motive.

Code of Professional Conduct for British Columbia (BC Code) · 2017 · archived copy · official source ↗

NZ Lawyers Conduct & Client Care Rules r 2.10 strong
A lawyer must not use, or threaten to use, the complaints or disciplinary process for an improper purpose.

Lawyers and Conveyancers Act (Lawyers: Conduct and Client Care) Rules 2008 · SR 2008/214 · archived copy · official source ↗

SCO Solicitors LSS Standards of Conduct no clear equivalent
SG Lawyers Professional Conduct Rules 2015 r 29 (Allegations against another legal practitioner) partial 6 cases
29 Allegations against another legal practitioner

Legal Profession (Professional Conduct) Rules 2015 · 2015 · archived copy · official source ↗

HK Solicitors Solicitors' Guide no clear equivalent
HK Barristers Bar Code of Conduct para 10.50 partial
A practising barrister shall not make any allegation of misconduct or dishonesty against another barrister unless such allegation is supported by reasonably credible evidence.

Code of Conduct of the Bar of the Hong Kong SAR · 2018 · archived copy · official source ↗

Cases dealing with this duty

Clear

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

  • CARMEL MARY FITZPATRICK
    LPBWA lawyer PO Box 812 MANDURAH WA 6210 Legal Profession Complaints Committee v Fitzpatrick [2011] WASAT 20 2011-02-02 found breached

    Professional Misconduct

    Professional Misconduct 1 PDF View decision
  • Hinde, Jeffrey James
    OLSC solicitor (Formerly) Jeffrey Hinde Solicitor [2011] NSWADT 20 2011-02-01 found breached

    1. Breach of Section 61(2) of the Legal Profession Act, 1987 - handling of trust moneys 2. Breach of Section 255(1)(b) of the Legal Profession Act, 2004 - requirements for the holding, disbursing and accounting for trus…

    Removal of practitioner's name from the Roll of Local Lawyers $0.00 View decision
  • Ogbondah Kkem Omodu
    SDT solicitor 10788/2011 2011-01-01 found breached

    Breaches, Failures, Others, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Bernard Rodney Brandon
    SDT solicitor 10717/2011 2011-01-01 found breached

    Breaches, Failures, Others

    Strike off 1 PDF View decision
  • Richard James Burley (J)
    SDT solicitor 10789/2011 2011-01-01 found breached

    Breaches, Failures, Others

    Strike off 1 PDF View decision
  • Miller, James Mathew
    OLSC barrister [2010] NSWADT 300 2010-12-17 found breached

    Professional Misconduct 1. Failed to comply with a notice pursuant to Section 660 of the Legal Profession Act 2004 Unsatisfactory Professional Conduct 2. Failed to provide tax invoices to client 3. Received trust money …

    Costs Fine Reprimand (20/06/2011 Disciplinary Action) $10,000.00 1 PDF View decision
  • David Christopher MACKIE
    LSC-QLD solicitor Gilshenan & Luton (now defunct) 2010-11-15 found breached

    Guilty of professional misconduct on 2 charges.

    other 1 PDF View decision
  • Edwin Mark DONNELLY
    LSC-QLD barrister N/A 2010-11-15 found breached

    Guilty of professional misconduct on 1 charge. Guilty of unsatisfactory professional conduct on 1 charge.

    other 1 PDF View decision
  • DAVID CHARLES LEASK
    LPBWA lawyer PO Box 1161 FREMANTLE WA 6959 Legal Profession Complaints Committee v Leask [2010] WASAT 2010-09-24 found breached

    Professional Misconduct

    Professional Misconduct 1 PDF View decision
  • AUGUSTUS ERNEST LEE-STEERE
    LPBWA lawyer PO Box 3455 NEDLANDS WA 6009 Legal Profession Complaints Committee v Lee-Steere [2010] WASAT 189 2010-08-31 found breached

    Professional Misconduct and Suspended

    Professional Misconduct and Suspended 1 PDF View decision
  • DAMIEN GERARD BRENNAN
    LPBWA lawyer 89 Duchess Street BUSSELTON WA 6280 Legal Profession Complaints Committee v Brennan [2010] WASC 198 2010-07-26 found breached

    Struck Off the Roll of Practitioners

    Struck Off the Roll of Practitioners 1 PDF View decision
  • David Santiago Morales
    GLC attorney 34 of 2009 2010-05-15 found breached

    Restitution Ordered | Disciplinary Committee decision delivered May 15, 2010. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO. 34/2009 IN THE MATTER OF EDNA THORPE v DAVID MORAL…

    Restitution Ordered 1 PDF View decision
  • PAUL ERNEST MASTEN
    LPBWA lawyer Suite 2 and Suite 11 16 Philimore Street FREMANTLE WA 6166 Legal Profession Complaints Committee v Masten [2010] WASAT 47 and [2010] WASAT 47 (S) 2010-04-08 found breached

    Professional Misconduct

    Professional Misconduct 2 PDFs View decision
  • DAMIEN GERARD BRENNAN
    LPBWA lawyer 89 Duchess Street BUSSELTON WA 6280 Legal Profession Complaints Committee v Brennan [2010] WASAT 46 2010-04-07 found breached

    Professional Misconduct

    Professional Misconduct 1 PDF View decision
  • MARTIN LEE SEGLER
    LPBWA lawyer 572 Hay Street PERTH WA 6000 Legal Practitioners Complaints Committee v Segler [2009] WASAT 205 and [2009] WASAT 205 (S) 2010-03-17 found breached

    Professional Misconduct and Suspended

    Professional Misconduct and Suspended 2 PDFs View decision
  • Trevor Ruddock
    GLC attorney 74 of 2003 2010-02-13 found breached

    Struck off, Repayment & Restitution Ordered | Disciplinary Committee decision delivered February 13, 2010. View PDF JUDGEMENT OF THE DISCIPLINARY COMMITTEE COMPLAINT NO. 74 OF 2003 BETWEEN JOAN BURKETT POWELL COMPLAINAN…

    Struck off, Repayment & Restitution Ordered 1 PDF View decision
  • Stephen Peter David Murrell
    SDT solicitor 10595/2010 2010-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Peter James Scott
    SDT solicitor 10551/2010 2010-01-01 found breached

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

    Strike off 1 PDF View decision
  • Endy Okoye & David Laryea
    SDT solicitor 10497/2010 2010-01-01 found breached

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

    Strike off 1 PDF View decision
  • Zahid Aziz Sheikh & Another
    SDT solicitor 10556/2010 2010-01-01 found breached

    Breaches, Client Money, Failures, Others

    Fine, Strike off 1 PDF View decision
  • Suresh Ladwa
    SDT solicitor 10681/2010 2010-01-01 found breached

    Others

    S.43 Order (clerks) 1 PDF View decision
  • M Rahman
    SDT solicitor 10608/2010 2010-01-01 found breached

    Breaches, Others

    Strike off 1 PDF View decision
  • J W Smith, A A Voliere, F Dawodu
    SDT solicitor 10431/2010 2010-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Strike off, Strike Off Register of Foreign Lawyers 1 PDF View decision
  • James Todd BRADSHAW
    LSC-QLD barrister N/A 2009-12-18 found breached

    Guilty of unprofessional conduct on 1 charge. Guilty of professional misconduct on 2 charges.

    other 1 PDF View decision
  • Georgette May Scott
    GLC attorney 15 of 2009 2009-12-18 found breached

    Leave to Appeal to Privy Council Denied, Court of Appeal & Disciplinary Committee Decisions upheld | Court of Appeal decision delivered December 18, 2009. View PDF JAMAICA SUPREME COURT CIVIL APPEAL NO. 118/2008 MOTION …

    Leave to Appeal to Privy Council Denied, Court of Appeal & Disciplinary Committee Decisions upheld 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.