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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

  • Zhang, Shijing
    OLSC solicitor Zhang Shijing Lawyers 2021-04-29 found breached

    Breached section 34 of the Legal Profession Uniform Law by failing to ensure an employed solicitor complied with her obligations under the Uniform Law Breached rule 37 of the Legal Profession Uniform Law Australian Soli…

    Fine Reprimand $12,000.00 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
  • W. Anthony Pearson
    GLC attorney 18 of 2018 2021-04-24 text match

    Guilty of Misconduct in a Professional Respect | Disciplinary Committee decision delivered April 24, 2021. || Fined | Disciplinary Committee decision delivered June 04, 2021. View PDF in Full Screen Back to top …

    Guilty of Misconduct in a Professional Respect 1 PDF View decision
  • Hunter, David Kevin
    OLSC solicitor David Hunter [2021] NSWCATOD 22 2021-02-23 text match

    Failure to comply with undertaking to retain moneys in trust account — Professional Misconduct

    Costs Fine Reprimand $6,000.00 Proceedings Instituted 1 PDF View decision
  • Arlean D. Moreta Beckford
    GLC attorney 135 of 2013 2021-01-26 found breached

    Struck off, Restitution Ordered | Disciplinary Committee decision delivered January 26, 2021. || Guilty of Professional Misconduct | Disciplinary Committee decision delivered January 13, 2021. View PDF DECISION ON SANCT…

    Struck off, Restitution Ordered 1 PDF View decision
  • David Johnson
    SDT solicitor 12266/2021 2021-01-01 found breached

    Breaches, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Graceann Marie Cameron
    GLC attorney 38 of 2015 2020-12-12 found breached

    Struck off, Restitution Ordered | Disciplinary Committee decision delivered December 12, 2020. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO: 38/2015 IN THE MATTER OF MELISA J…

    Struck off, Restitution Ordered 1 PDF View decision
  • James Beresford Loel
    LSC-QLD solicitor Lilas & Loel Lawyers 2020-07-15 found breached

    On each of Charges 11, 13, 14, 15 and 17, there is a finding that the respondent engaged in professional misconduct. On each of Charges 1, 2, 3, 4, 5, 6, 7 and 10, there is a finding that the respondent engaged in unsat…

    Suspended 1 PDF View decision
  • Malcolm Tan Chun Chuen
    SG-DT lawyer Malcolm Tan Chambers LLC 2020-07-06 found breached
    Struck off the roll with immediate effect 1 PDF View decision
  • Bunton, Barry
    OLSC solicitor Bunton Lawyers [2020] NSWCATOD 67 2020-06-22 text match

    Failure to comply with undertaking to Law Society of NSW to attain CPD points — Professional Misconduct

    Costs Reprimand $0.00 Proceedings Instituted 1 PDF View decision
  • Barbara Ledgister
    GLC attorney 111 of 2019 2020-06-16 rule cited

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered June 16, 2020 | Suspended | Disciplinary Committee decision delivered December 06, 2023. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF T…

    Guilty of Professional Misconduct 2 PDFs View decision
  • Jiao, Stephen
    OLSC solicitor Loyal One Solicitors [2020] NSWCATOD 63 2020-06-15 text match

    1. Failure to comply with a practising certificate condition 2. Failure to comply with an undertaking — Professional Misconduct

    Costs Fine Reprimand $5,000.00 Proceedings Instituted 1 PDF View decision
  • Lo, Tan Dinh
    OLSC solicitor Lelo Lawyers 2020-03-19 text match

    1. Failed to carry out instructions 2. Failed to comply with an undertaking — 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
  • Carr, Malcolm Douglas
    OLSC solicitor MC Solicitor Pty Limited [2020] NSWCATOD 5 2020-01-14 text match

    1. Attempting to mislead re no funds held in trust 2. Failure to comply with undertaking to transfer trust monies 3. Misappropriation of trust monies — Professional Misconduct Unsatisfactory Professional Conduct

    To be determined by the Tribunal $0.00 Proceedings Instituted 1 PDF View decision
  • Richard Mallett & Sharon Mallett
    SDT solicitor 12102/2020 2020-01-01 found breached text match

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Jonathan Thomas Gorman
    SDT solicitor 12086/2020 2020-01-01 found breached text match

    Breaches, Failures

    Strike off 1 PDF View decision
  • Richard Clive Hallows
    SDT solicitor 12094/2020 2020-01-01 found breached

    Breaches, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • James (Seamus) Doody
    LSI solicitor Doody Solicitors, 21 South Mall, Cork 2019-10-18 text match

    In the matter of James (Seamus) Doody, solicitor, practising in Doody Solicitors, 21 South Mall, Cork, and in the matter of an application by the Law Society of Ireland to the Solicitors Disciplinary Tribunal [6285/DT17…

    strike_off View decision
  • James (Seamus) Doody
    LSI solicitor Doody Solicitors, 21 South Mall, Cork 2019-10-18 found breached

    In the matter of James (Seamus) Doody, solicitor, practising in Doody Solicitors, 21 South Mall, Cork, and in the matter of an application by the Law Society of Ireland to the Solicitors Disciplinary Tribunal [2017/DT84…

    strike_off View decision
  • Maurice B O’Sullivan
    LSI solicitor Maurice O’Sullivan & Company Solicitors, 9 Colbert Street, Listowel, Co Kerry 2019-10-14 text match

    In the matter of Maurice B O’Sullivan, a solicitor practising as Maurice O’Sullivan & Company Solicitors, at 9 Colbert Street, Listowel, Co Kerry, and in the matter of the Solicitors Acts 1954-2015 [2017/DT24, 2017/DT38…

    strike_off View decision
  • Michael Doody
    LSI solicitor Doody Solicitors, 21 South Mall, Cork 2019-10-10 found breached

    In the matter of Michael Doody, solicitor, principal at Doody Solicitors, 21 South Mall, Cork, and in the matter of an application by the Law Society of Ireland to the Solicitors Disciplinary Tribunal [2017/DT85 and 201…

  • NICHOLAS NEIL PETER OUD
    LPBWA lawyer PO Box 326 BURSWOOD WA 6100 Legal Profession Complaints Committee v Oud [2019] WASC 2019-07-31 text match

    Struck Off the Roll of Practitioners

    Struck Off the Roll of Practitioners 1 PDF View decision
  • Raymond Clough
    GLC attorney 186 of 2010 2019-07-26 text match

    Suspended, Fined - Disciplinary Committee decision delivered July 26, 2019. | Guilty of Professional Misconduct - Disciplinary Committee decision May 11, 2019. | Formal Order July 26, 2019 View PDF DECISION OF THE DISCI…

    Suspended, Fined - Disciplinary Committee decision delivered July 26, 2019. 1 PDF View decision
  • Lewis, Paul Edward
    OLSC solicitor Total Legal [2019] NSWCATOD 100 2019-06-24 text match

    1. Contravened a condition on his practising certificate 2. Failed to comply with undertaking to the Law Society of NSW — Professional Misconduct

    Costs Fine Reprimand $4,000.00 Proceedings Instituted 1 PDF View decision
  • Petrovich, Vic
    OLSC solicitor Petrovich Law Group Pty Ltd [2019] NSWCATOD 44 2019-03-28 text match

    Failure to comply with undertakings — Professional Misconduct

    Costs Reprimand $0.00 Proceedings Instituted 1 PDF View decision
  • Powell, Helen Jean
    OLSC solicitor Helen Powell Legal Pty Ltd [2019] NSWCATOD 24 2019-02-15 text match

    1. Failed to comply with undertaking 2. Contravened a condition on practising certificate — Professional Misconduct

    Costs Fine Reprimand $1,000.00 Proceedings Instituted 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.