Skip to main content
discipline 4 October 2026

The duty in context

No baseless or threatened misconduct report profession

The lawyer must not make or threaten a professional-misconduct allegation or report without a genuine, reasonably held and bona fide belief that it applies.

505 cases 43% strike-off avg suspension 15.0 mo avg fine 83,213 198 with dishonesty finding

How the codes express this duty

E&W Solicitors SRA Principles & Code no clear equivalent
E&W Barristers BSB Handbook rC67 strong 28 cases
rC67 You must never make, or threaten to make, a report under Rule rC66 without a genuine and reasonably held belief that Rule rC66 applies.
Cayman Islands Legal Services Code 2026 no clear equivalent
AU Solicitors Solicitors' Conduct Rules Rule 32.1 strong 198 cases
A solicitor must not make an allegation against another Australian legal practitioner of unsatisfactory professional conduct or professional misconduct unless the allegation is made bona fide and the solicitor believes on reasonable grounds that available material by which the allegation could be supported provides a proper basis for it.
AU Barristers Uniform Barristers Rules no clear equivalent
IE Solicitors Law Society Guide no clear equivalent
IE Barristers Bar Code of Conduct no clear equivalent
JM Attorneys Canons of Professional Ethics no clear equivalent
JE Lawyers Law Society of Jersey Code no clear equivalent
ON Lawyers LSO Rules of Prof. Conduct r 3.2-5(b); r 7.1-3 commentary [1] partial
3.2-5 A lawyer shall not, in an attempt to gain a benefit for a client, threaten, or advise a client to threaten, without reasonable and lawful justification ... (b) to make a complaint to a regulatory authority. [7.1-3 commentary [1]: In all cases, the report must be made without malice or ulterior motive. 3.2-5 commentary [1]: It is an abuse of the process of a court or, ordinarily, a regulatory authority to threaten to make or advance a charge or complaint in order to secure the satisfaction of a private grievance.]
BC Lawyers BC Code r 7.1-3, commentary [2] partial 37 cases
Nothing in this paragraph is meant to interfere with the lawyer-client relationship. In all cases, the report must be made without malice or ulterior motive.
NZ Lawyers Conduct & Client Care Rules r 2.10 strong
A lawyer must not use, or threaten to use, the complaints or disciplinary process for an improper purpose.
SCO Solicitors LSS Standards of Conduct no clear equivalent
SG Lawyers Professional Conduct Rules 2015 r 29 (Allegations against another legal practitioner) partial 6 cases
29 Allegations against another legal practitioner
HK Solicitors Solicitors' Guide no clear equivalent
HK Barristers Bar Code of Conduct para 10.50 partial
A practising barrister shall not make any allegation of misconduct or dishonesty against another barrister unless such allegation is supported by reasonably credible evidence.

Cases dealing with this duty

Clear

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

  • Arnaldo Alphanso Brown
    GLC attorney 136 of 2017 2018-04-14 found breached

    Fined | Disciplinary Committee decision delivered April 14, 2018. View PDF FORMAL ORDER OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO: 136/2017 IN THE MATTER OF GENERAL LEGAL COUNCIL (ALLAN WOO…

    Fined 1 PDF View decision
  • Michael James QUINN
    LSC-QLD solicitor Q5 Law Pty Ltd 2018-04-07 found breached

    Guilty of professional misconduct on all charges.

    Struck off 1 PDF View decision
  • Luke James MCDONALD
    LSC-QLD solicitor Corrs Chambers Westgarth 2018-03-15 found breached

    Guilty Professional misconduct on both charges.

    other 1 PDF View decision
  • Penelope Ann CORBETT
    LSC-QLD solicitor Cost Effective Lawyers 2018-02-15 found breached

    Guilty - professional misconduct on both charges

    other 1 PDF View decision
  • Ashton Lloyd Doherty
    SDT solicitor 11874/2018 2018-01-01 found breached

    Breaches, Failures

    Strike off 1 PDF View decision
  • Kessar Nabi
    SDT solicitor 11896/2018 2018-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Lee Lipson
    SDT solicitor 11860/2018 2018-01-01 found breached

    Criminal Convictions

    Strike off 1 PDF View decision
  • Baljinder Hayre
    SDT solicitor 11834/2018 2018-01-01 found breached

    Breaches

    Strike off 1 PDF View decision
  • Edward Sibley
    SDT solicitor 11780/2018 2018-01-01 found breached

    Breaches, Client Money, Solicitors' Accounts Rules

    Fine, Strike off 1 PDF View decision
  • Richard Charles Prescott
    SDT solicitor 11783/2018 2018-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Jermaine Ryan Simms
    GLC attorney 48 of 2009 2017-10-12 found breached

    Restitution Ordered | Disciplinary Committee decision delivered October 12, 2017. View PDF View Decision SANCTION DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO: 48/2009 IN THE MATTER O…

    Restitution Ordered 1 PDF View decision
  • Alexia Margaret WARREN
    LSC-QLD solicitor Lexie Warren Solicitor 2017-05-26 found breached

    The respondent's conduct amounted to Professional Misconduct

    other 1 PDF View decision
  • Craig Selwyn Lee JENSEN
    LSC-QLD solicitor Dr Craig Jensen Lawyers 2017-05-22 found breached rule cited

    Guilty of Professional Misconduct

    other 1 PDF View decision
  • Russell William Tracy BIDDLE
    LSC-QLD solicitor Biddle Lawyers 2017-04-27 found breached

    Professional misconduct (theft of a total of $1,821,230.59 from two of his clients' estates)

    other 1 PDF View decision
  • Mahnoor Choudhury
    BTAS barrister Lincoln's Inn 2017-04-19 found breached
    strike_off Final 1 PDF View decision
  • Jodi Leigh DINGWALL
    LSC-QLD solicitor Roverts Nehmer McKee 2017-03-21 found breached

    3 Charges of Delay and Failure to advance a client's actions - Proven. 3 Charges of False Representations - Proven.

    other 1 PDF View decision
  • PETER CHRISTISON NEIL
    LPBWA lawyer 23/40 Mount Street WEST PERTH WA 6004 Legal Profession Complaints Committee v Neil [2017] WASAT 48 and [2017] WASAT 48 (S) 2017-03-17 found breached

    Professional Misconduct and conditions imposed

    Professional Misconduct and conditions imposed 2 PDFs View decision
  • RONALD WILLIAM BOWER
    LPBWA lawyer Level 4, Irwin Chambers 16 Irwin Street PERTH WA 6000 Legal Profession Complaints Committee v Bower [2017] WASAT 2017-03-17 found breached

    Professional Misconduct

    Professional Misconduct 2 PDFs View decision
  • Chad Everett ROWE
    LSC-QLD solicitor Rowe Lawyers Pty Ltd 2017-03-10 found breached

    28 Charges of professional misconduct proven

    other 1 PDF View decision
  • John Gerard O'Donnell
    SSDT solicitor John Gerard O’Donnell, formerly of 14 Winton Drive, Glasgow and now residing at Flat 1/2, 322 Kelvindale Road, Glasgow 2017-02-15 found breached
    strike_off No Appeal 4 PDFs View decision
  • Andrew John Peters
    SDT solicitor 11746/2017 2017-01-01 found breached

    Criminal Convictions

    Strike off 1 PDF View decision
  • Rodney Richard BUDGEN
    LSC-QLD solicitor Budgen Lawyers 2016-12-22 found breached

    Professional misconduct

    other 4 PDFs View decision
  • Robert John GOULD
    LSC-QLD solicitor HSH Lawyers 2016-12-16 found breached

    Unprofessional conduct and Professional Misconduct

    other 1 PDF View decision
  • Ashworth, Gary John
    OLSC solicitor Ashlaw Associates [2016] NSWCATOD 139 2016-11-11 found breached

    Misappropriation of trust funds 1. Breach of section 255 LPA 2004 - Holding, disbursing and accounting for trust money 2. Breach of section 263 LPA 2004 - Reporting certain irregularities and suspected irregularities 3.…

    Costs Removal of practitioner's name from the Roll of Local Lawyers $0.00 1 PDF View decision
  • Peter John WATTS
    LSC-QLD solicitor Watts & Company 2016-09-06 found breached

    Guilty of professional misconduct.

    other 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.