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.
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.
SRA Code of Conduct for Solicitors, RELs and RFLs · 2019 · archived copy · official source ↗
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.
BSB Handbook · current · archived copy · official source ↗
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.
Cayman Islands Legal Services Code of Professional Conduct · 2026 · archived copy
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.
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 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.
Solicitor's Guide to Professional Conduct (Law Society of Ireland) · 4th ed. (2022) · archived copy · official source ↗
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.
Legal Profession (Canons of Professional Ethics) Rules · 1978 (principal) · archived copy · official source ↗
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.
Law Society of Jersey Code of Conduct · 1 January 2017 · archived copy · official source ↗
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.]
Law Society of Ontario — Rules of Professional Conduct · current · archived copy · official source ↗
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.
Code of Professional Conduct for British Columbia (BC Code) · 2017 · archived copy · official source ↗
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.
Lawyers and Conveyancers Act (Lawyers: Conduct and Client Care) Rules 2008 · SR 2008/214 · archived copy · official source ↗
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.
Law Society of Scotland — Practice Rules 2011, Rule B1 (Standards of Conduct) · 2011 · archived copy · official source ↗
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
Legal Profession (Professional Conduct) Rules 2015 · 2015 · archived copy · official source ↗
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.
Hong Kong Solicitors' Guide to Professional Conduct (Volume 1) · current · archived copy · official source ↗
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.
Code of Conduct of the Bar of the Hong Kong SAR · 2018 · archived copy · official source ↗
Cases dealing with this duty
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
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Vosnakis, Joseph Con
Breach of undertaking — A reasonable likelihood of a finding of 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 -
Ronald Frank Maclean Williamson
Breaches, Failures, Solicitors' Accounts Rules, Others
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H Singh and Another
Client Money, Failures, Solicitors' Accounts Rules
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Richard Mark Baker
Breaches, Client Money, Delays, Failures, Solicitors' Accounts Rules, Others
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Peter Madu Obidi
Criminal Convictions, Failures, Solicitors' Accounts Rules, Others
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Purcell Robert Michael Brown
Breaches, Client Money, Failures, Solicitors' Accounts Rules
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Myles MacGregor Austin-Olsen
Client Money, Failures, Solicitors' Accounts Rules, Others
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9247-2005 - John Stuart Baker
Breaches, Client Money, Others
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Liaqat Ali
Others
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Christopher Onyeka Agwu & Another
Client Money, Failures, Solicitors' Accounts Rules, Others
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Stephen Morecroft
Breaches, Client Money, Failures, Solicitors' Accounts Rules, Others
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Knudsen, Peter Stanley
Professional Misconduct: 1. Breach of Section 61 of the Legal Profession Act 1987 - handling of trust moneys (Fine $10,000) 2. Attempting to influence a witness not to give evidence in disciplinary proceedings (Repriman…
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Krayem, Ghaith
1. Breach Clause 36 of the Legal Profession Regulation 1994 by failing to prepare monthly bank reconciliations 2. Breach Clause 39 of the Legal Profession Regulation 1994 by failing to prepare monthly trial balances of …
Costs Removal of practitioner's name from the Roll of Local Lawyers $0.00 Proceedings Instituted 1 PDF View decision -
Witherdin, Michael Dominic
1. Fail to carry out instructions 2. Breach of undertaking to Law Society 3. Mislead client 4. Breach of Section 61 of Legal Profession Act 1987 - handling of trust monies 5. Failure to respond to practitioner 6. Delay …
Cancellation of Practising Certificate from 01/01/2005 and Practising Certificate not to be re-issued until 18 months after 01/01/2005 $0.00 Proceedings Instituted View decision -
Peter Fortune
Before the president the High Court: in the matter of Peter Fortune, solicitor, formerly practising under the style and title of Peter M Fortune & Co, Solicitors, at 38 Molesworth Street, Dublin 2, and in the matter of …
strike_off View decision -
Zahir Ahmed Aziz
Breaches, Client Money, Failures, Solicitors' Accounts Rules, Others
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K W Good, G M Cardona and A E A Davies
Breaches, Client Money, Criminal Convictions, Failures
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Sean Martin
Others
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Raymond John Holland
Breaches, Client Money, Failures, Solicitors' Accounts Rules, Others
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S J Ryan and S J Pyke
Breaches, Client Money, Failures, Solicitors' Accounts Rules, Others
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John Lionel Reeves
Breaches, Failures, Others
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Amarjit Singh Devgun
Breaches, Delays, Failures, Solicitors' Accounts Rules, Others
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Goldberg, Charles Alroy
Failure to comply with undertaking — Professional Misconduct
Reprimand $0.00 Proceedings Instituted View decision -
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Smith, Mark Duncan
1. Fail to return documents 2. Breach of undertakings to do so — Unsatisfactory Professional Conduct
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.