(unnamed respondent)

Findings — machine-extracted (anthropic-batch:claude-opus-4-8); verify against the decision

This was a section 47 application by Queen Appahoh to remove practice restrictions imposed following a 2020 Agreed Outcome (12-month suspension plus conditions) relating to non-dishonest but serious regulatory failures at Bilsan Henaku Solicitors that caused significant client financial loss. Applying the proportionality test in Bryant v SRA, the Tribunal found the Applicant had not demonstrated a sufficient material change in circumstances, showed limited insight (notably regarding client loss), had failed to disclose a December 2022 regulatory warning, and provided no evidence of sustained supervised practice. The restrictions were found to remain necessary, reasonable and proportionate for public protection, so the application was refused. Costs were sought at £6,878 but reduced to £1,500 for proportionality and the Applicant's limited means.

Duties found breached:

• Comply with and respect court orders
• No improper use of client money
• Accounting records, reconciliation and reports
• Not misrepresent regulated status

Aggravating factors:

• Original misconduct resulted in significant financial loss to a client
• Limited insight, particularly regarding client financial loss
• Failure to disclose the December 2022 regulatory warning in the application
• Discrepancies regarding continuity of practising certificate
• Lack of sustained compliant practice under supervision

Mitigating factors:

• No finding of dishonesty in original proceedings
• Some training, mentoring and voluntary work undertaken
• No further misconduct or client complaints since conditions imposed
• Restrictions had adverse impact on employment; reliant on state benefits