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discipline 4 October 2026

The duty in context

No conflict between current clients client

The lawyer must not act for two or more current clients with conflicting interests except within defined exceptions with each client's informed consent and protection of confidentiality.

1,286 cases 62% strike-off avg suspension 13.6 mo avg fine 150,323 627 with dishonesty finding

How the codes express this duty

E&W Solicitors SRA Principles & Code CCS 6.2 strong 824 cases
6.2 You do not act in relation to a matter or particular aspect of it if you have a conflict of interest or a significant risk of such a conflict in relation to that matter or aspect of it, unless: (a) the clients have a substantially common interest ...; or the clients are competing for the same objective, and the conditions below are met ...
E&W Barristers BSB Handbook rC21.3; gC69 strong 32 cases
rC21.3 there is a conflict of interest, or real risk of conflict of interest, between the prospective client and one or more of your former or existing clients in respect of the particular matter unless all of the clients who have an interest in the particular matter give their informed consent to your acting in such circumstances;
Cayman Islands Legal Services Code 2026 R.7.1; R.7.2; R.7.3 strong
Except in the limited circumstances dealt with in R.7.3, an attorney-at-law or a recognised law entity shall not act if there is a conflict of interests or a significant risk of a conflict... may act, in non-contentious matters, for more than one client whose interests conflict in the matter only with the informed written consent of all clients.
AU Solicitors Solicitors' Conduct Rules Rules 11.1; 11.2; 11.3; 11.4 strong 134 cases
11.1 A solicitor and a law practice must avoid conflicts between the duties owed to two or more current clients. 11.2 If a solicitor or a law practice seeks to act for two or more clients in the same or related matters where the clients' interests are adverse and there is a conflict or potential conflict... the solicitor or law practice must not act, except where permitted by Rules 11.3 and 11.4.
AU Barristers Uniform Barristers Rules r113 strong 39 cases
A barrister who is briefed to appear for two or more parties in any case must determine as soon as possible whether the interests of the clients may, as a real possibility, conflict and, if so, the barrister must then return the brief for: (a) all the clients in the case of confidentiality to which Rule 108 would apply; or (b) one or more of the clients so as to remove that possibility of conflict.
IE Solicitors Law Society Guide Ch3 — General; Conflict of interest between two clients; Non-conveyancing transactions strong 48 cases
A solicitor should not act in a matter, or any part of a matter, where there is a conflict of interest... If a solicitor, acting with ordinary care, would give different advice to different clients about the same matter, there is a conflict of interest, and the solicitor should not act for both clients... Where clients consent to one firm representing both parties to a non-conveyancing transaction, the law requires that each client gives informed consent.
IE Barristers Bar Code of Conduct Rule 3.16; Rule 10.10 partial 48 cases
In cases involving several parties, Barristers on receipt of instructions for more than one of such parties should consider whether or not any conflict arises as between the individual interests of each of the clients and they shall advise the solicitor as to whether any of the clients should be separately advised and represented by a Barrister or solicitor. ... Barristers may appear for more than one defendant in a criminal trial provided they have satisfied themselves that there is no conflict of interest.
JM Attorneys Canons of Professional Ethics Canon IV(k); Canon IV(l); Canon IV(m) strong 133 cases
Subject to the provisions of Canon IV (l), an Attorney shall not accept or continue his retainer or employment on behalf of two or more clients if their interests are likely to conflict or if the independent professional judgment of the Attorney is likely to be impaired. (l) Notwithstanding the provisions of Canon IV (k), an Attorney may represent multiple clients if he can adequately represent the interests of each and if each consent to such representation after full disclosure of the possible effects of such multiple representation.
JE Lawyers Law Society of Jersey Code R.6.1; R.6.3 strong
Except in the limited circumstances dealt with in R.6.3, a member or their firm must not act if there is a conflict of interests or a significant risk of a conflict... A member or their firm may act, in non-contentious matters, for more than one client whose interests conflict in the matter only with the informed written consent of all clients.
ON Lawyers LSO Rules of Prof. Conduct r 3.4-2; r 3.4-3 strong
3.4-2 A lawyer shall not represent a client in a matter when there is a conflict of interest unless there is consent, which must be fully informed and voluntary after disclosure, from all affected clients and the lawyer reasonably believes that he or she is able to represent each client without having a material adverse effect upon the representation of or loyalty to the other client. [3.4-3 Despite rule 3.4-2, a lawyer shall not represent opposing parties in a dispute.]
BC Lawyers BC Code r 3.4-2 strong 34 cases
A lawyer must not represent a client in a matter when there is a conflict of interest unless there is express or implied consent from all clients and the lawyer reasonably believes that he or she is able to represent each client without having a material adverse effect upon the representation of or loyalty to the other client.
NZ Lawyers Conduct & Client Care Rules r 6.1 strong
A lawyer must not act for more than 1 client on a matter in any circumstances where there is a more than negligible risk that the lawyer may be unable to discharge the obligations owed to 1 or more of the clients.
SCO Solicitors LSS Standards of Conduct B1.7 strong 56 cases
You must not act for two or more clients in matters where there is a conflict of interest between the clients or for any client where there is a conflict between the interest of the client and your interest or that of your practice unit.
SG Lawyers Professional Conduct Rules 2015 r 20 (Conflict, or potential conflict, between interests of 2 or more clients) strong 13 cases
20 Conflict, or potential conflict, between interests of 2 or more clients
HK Solicitors Solicitors' Guide Principle 9.01 strong
A solicitor or firm of solicitors must not accept instructions to act for two or more clients where there is a conflict or a significant risk of conflict between the interests of those clients.
HK Barristers Bar Code of Conduct para 10.14(a) strong
If after he has accepted the brief or instructions on behalf of more than one lay client, there is or appears to be a conflict or a risk of conflict between the interests of any one or more of such clients, he must not continue to act for any client unless all such clients give their consent to his so acting and he can do so without embarrassment.

Cases dealing with this duty

Clear

1,286 decisions · link basis: found breached = a tribunal finding; rule cited = the mapped provision is cited in the decision; text match = high-precision text pattern

  • John Graham Lints
    SSDT solicitor John Graham Lints, 1/6 Succoth Avenue, Edinburgh 2013-07-16 found breached
    strike_off No Appeal 1 PDF View decision
  • Adam A Suzin
    LSI solicitor Adam A Suzin & Co, Solicitors, 6 Keon’s Terrace, Longford, Co Longford 2013-07-08 found breached

    In the matter of Adam A Suzin, a solicitor formerly practising as Adam A Suzin & Co, Solicitors, 6 Keon’s Terrace, Longford, Co Longford, and in the matter of the Solicitors Acts 1954-2008 [10064/DT103/11 and High Court…

    strike_off View decision
  • Colin George Horne Wilson
    SSDT solicitor Colin George Horne Wilson, 25 Jamaica Street, Aberdeen 2013-06-11 found breached
    strike_off No Appeal 1 PDF View decision
  • Angelovski, Lupco Vanchov
    OLSC solicitor (Formerly) B J Murphy Angelovski & Associates|(Formerly) Morgan Ardino & Co [2013] NSWADT 93 2013-05-02 found breached

    1. Failed to attend court to instruct Counsel when instructed to do so and when in receipt of a grant of Legal Aid to so attend 2. Failed to act in accordance with Legal Aid Practice Standards 3. Recklessly misled the O…

    Additional Orders made by the Tribunal (see Tribunal decision) Reprimand $0.00 View decision
  • Patrick Aidan Crowley
    LSI solicitor Egan Daughter & Company, Solicitors, Church Street, Castlebar, Co Mayo 2013-04-15 found breached

    In the matter of Patrick Aidan Crowley, a solicitor previously practising as a partner in the firm of Egan Daughter & Company, Solicitors, Church Street, Castlebar, Co Mayo, and in the matter of the Solicitors Acts 1954…

  • Patrick McCarthy
    LSI solicitor McCarthy & Co, Second Floor, Building 1000, City Gate, Mahon, Cork 2013-04-08 found breached

    In the matter of Patrick McCarthy, solicitor, formerly practising as McCarthy & Co, Second Floor, Building 1000, City Gate, Mahon, Cork, and in the matter of the Solicitors Acts 1954-2011 [7748/DT120/11 and High Court r…

    strike_off View decision
  • Patrick McCarthy
    LSI solicitor McCarthy & Co, Second Floor, Building 1000, City Gate, Mahon, Cork 2013-04-08 found breached

    In the matter of Patrick McCarthy, solicitor, formerly practising as McCarthy & Co, Second Floor, Building 1000, City Gate, Mahon, Cork, and in the matter of the Solicitors Acts 1954-2011 [7748/DT131/10 and High Court r…

    strike_off View decision
  • Patrick McCarthy
    LSI solicitor McCarthy & Co, Second Floor, Building 1000, City Gate, Mahon, Cork 2013-04-08 found breached

    In the matter of Patrick McCarthy, solicitor, formerly practising as McCarthy & Co, Second Floor, Building 1000, City Gate, Mahon, Cork, and in the matter of the Solicitors Acts 1954-2011 [7748/DT144/11 and High Court r…

    strike_off View decision
  • Flynn, Mark Joseph
    OLSC solicitor (Formerly) Mark Flynn & Associates Pty Ltd [2013] NSWADT 70 2013-04-03 found breached

    Professional Misconduct: 1. Produced false trust account records 2. Breached his written undertaking 3. Attempted to mislead client's former solicitor 4. Failed to comply with undertaking dated 8 December 2008 5. Commun…

    Costs Removal of practitioner's name from the Roll of Local Lawyers $0.00 View decision
  • Padraig J Butler
    LSI solicitor Butler Solicitors, 10 Lower Patrick Street, Kilkenny 2013-01-28 found breached

    In the matter of Padraig J Butler, solicitor, formerly practising as Butler Solicitors at 10 Lower Patrick Street, Kilkenny, and in the matter of the Solicitors Acts 1954-2008 [2908/DT121/11 and 2908/DT104/12] Law Socie…

    strike_off View decision
  • Seamus P McConnell
    LSI solicitor Tullamore, Co Offaly 2013-01-28 found breached

    In the matter of Seamus P McConnell, solicitor, of Tullamore, Co Offaly, and in the matter of the Solicitors Acts 1954-2008 [6626/DT83/11, 6626/DT84/11 and High Court record 2012 no 87SA] Law Society of Ireland (applica…

    conditions View decision
  • Brendan MacNamara
    LSI solicitor Devitt Doorley MacNamara, The Valley, Roscrea, Co Tipperary 2013-01-21 found breached

    In the matter of Brendan MacNamara, solicitor, formerly practising as a partner in the practice of Devitt Doorley MacNamara, The Valley, Roscrea, Co Tipperary, and in the matter of the Solicitors Acts 1954-2011 [10447/D…

    strike_off View decision
  • Katherine Anne Edwards
    SDT solicitor 11190/2013 2013-01-01 found breached

    Breaches, Failures, Others

    Strike off 1 PDF View decision
  • Ziad Al-Rawi
    SDT solicitor 11168/2013 2013-01-01 found breached

    Breaches, Client Money, Failures, Others

    Strike off 1 PDF View decision
  • Toper Hassan
    SDT solicitor 11125/2013 2013-01-01 found breached

    Failures, Others

    Suspend - Indefinite 1 PDF View decision
  • Michael Gerald Dotchon
    SDT solicitor 11153/2013 2013-01-01 found breached

    Breaches, Client Money, Failures, Others

    Strike off 1 PDF View decision
  • David Nigel Bird
    SDT solicitor 11139/2013 2013-01-01 found breached

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

    Strike off 1 PDF View decision
  • Princewill Edwin Anyakudo
    SDT solicitor 11118/2013 2013-01-01 found breached

    Client Money, Failures, Others

    S.43 Order (clerks) 1 PDF View decision
  • Ritesh Jayendra Brahmbhatt
    SDT solicitor 11149/2013 2013-01-01 found breached

    Criminal Convictions

    Strike off 1 PDF View decision
  • Denis Francis McKay & Stuart Roger Turner
    SDT solicitor 11123/2013 2013-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Paul Francis Fallon
    SDT solicitor 11163/2013 2013-01-01 found breached

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

    Strike off 1 PDF View decision
  • Stephen Leslie Hiseman
    SDT solicitor 11137/2013 2013-01-01 found breached

    Breaches, Failures, Others

    S.43 Order (clerks) 1 PDF View decision
  • Ashok Kumar Sancheti
    SDT solicitor 11143/2013 2013-01-01 found breached

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

    Strike off 1 PDF View decision
  • Kimberley Bridge & John Charles McNabb & Tracy Stansfield & Nicola Roach
    SDT solicitor 11181/2013 2013-01-01 found breached

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

    Fine, Reprimand, S.43 Order (clerks), Strike off 1 PDF View decision
  • Campbell Dinsmore Joss
    SSDT solicitor Campbell Dinsmore Joss, Unit 4, 1987 Maryhill Road, Glasgow 2012-12-18 found breached
    strike_off No Appeal 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.