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discipline 3 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

  • Andrew Roman Pena
    SDT solicitor 12142/2020 2021-03-18 found breached

    Breaches, Client Money, Dishonesty, Failures, Lack of Integrity, Misappropriation of Client Account, Solicitors Accounts Rules 2011, SRA Principles 2011

    Strike off 1 PDF View decision
  • Sonia Sukhdeesh Hayer
    LSBC lawyer 2021-03-05 found breached

    Rule 3-7.1 Consent Agreement | Summary

    Rule 3-7.1 Consent Agreement | Summary 1 PDF View decision
  • David Wedge
    BTAS barrister Middle Temple 2021-01-25 found breached
    strike_off Final 1 PDF View decision
  • Matthew Boyden
    BTAS barrister Middle Temple 2021-01-21 found breached
    conditions Final 2 PDFs View decision
  • Arlean D. Moreta Beckford
    GLC attorney 135 of 2013 2021-01-13 found breached

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

    Guilty of Professional Misconduct 1 PDF View decision
  • Julia Cooper
    SDT solicitor 12213/2021 2021-01-01 found breached

    Breaches, Failures

    Strike off 1 PDF View decision
  • Caroline Jones & Hillyer McKeown LLP
    SDT solicitor 12262/2021 2021-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Fine 1 PDF View decision
  • Mia Branchette
    SDT solicitor 12229/2021 2021-01-01 found breached

    Breaches

    Strike off 1 PDF View decision
  • Simon Sui Ping Hsu
    SDT solicitor 12181/2021 2021-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Margaret Bridget Hetherington & Patrick Clement Hetherington
    SDT solicitor 12175/2021 2021-01-01 found breached

    Breaches, Failures

    Strike off 1 PDF View decision
  • Mohammed Arshad Amin
    SDT solicitor 12173/2021 2021-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Sam Themis
    SDT solicitor 12212/2021 2021-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Seth Lovis
    SDT solicitor 12203/2021 2021-01-01 found breached

    Breaches, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Wahid Nazari
    SDT solicitor 12188/2021 2021-01-01 found breached

    Criminal Convictions

    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
  • Dib, Ghassan
    OLSC solicitor CCL Pty Ltd 2020-11-26 found breached

    Breach of section 260 LPA 2004 - Intermixing money Caused a deficiency in the trust account Breach of section 264(2) LPA 2004 - Keeping trust records Breach of section 147(2) LPUL (NSW) - Keeping trust records Failure t…

    Fine Practitioner to undertake and complete further legal education Reprimand $4,362.28 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
  • Thorpe, Terrance William
    OLSC barrister Sir Owen Dixon Chambers [2020] NSWCATOD 133 2020-11-24 found breached

    Ground 1: Breached Rule 62 of the Bar Rules when he failed to inform the defence representatives, or the Court: (a) of the fact that a key prosecution witness said at a witness conference, attended by the Respondent on …

    Reprimand $0.00 1 PDF View decision
  • John Charles Nason Craxton
    SSDT solicitor John Charles Nason Craxton, residing at 2A Ashton View, Dumbarton 2020-11-09 found breached
    strike_off No Appeal 1 PDF View decision
  • Bayard, Jacinta Louise
    OLSC solicitor Bayard Law Pty Ltd 2020-11-05 found breached

    1. Transfer trust money from controlled money account without proper authority, in breach of section 139 of the Legal Profession Uniform Law (NSW) 2. Failed to provide statements in relation to the trust account when re…

    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
  • Christopher James Rosser
    LSC-QLD barrister 2020-10-20 found breached

    On each of Charges 1, 3, 4, 5, 9, 10 and 11 the respondent engaged in professional misconduct

    Struck off 1 PDF View decision
  • Arlene Ann Gaynor
    GLC attorney 88 of 2018 2020-08-18 found breached

    Struck off, Restitution Ordered | Disciplinary Committee decision delivered August 18, 2020. || Guilty of Professional Misconduct | Disciplinary Committee decision delivered July 29, 2020. View PDF DECISION OF THE DISCI…

    Struck off, Restitution Ordered 1 PDF View decision
  • Arlene Ann Gaynor
    GLC attorney 88 of 2018 2020-07-29 found breached

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered July 29, 2020. || Struck off, Restitution Ordered | Disciplinary Committee decision delivered August 18, 2020. View PDF DECISION OF THE DISCI…

    Guilty of Professional Misconduct 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
  • Barbara Ledgister
    GLC attorney 111 of 2019 2020-06-16 found breached

    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

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.