Decision record
Andrew John Puddicombe
Allegation / charges
Breaches, Solicitors' Accounts Rules
Findings — machine-extracted (anthropic-batch:claude-opus-4-8); verify against the decision
Andrew John Puddicombe, an immigration/asylum solicitor employed by the Gloucester Law Centre (a charity that did not charge for services), covertly charged clients privately between November 2012 and October 2015 without his employer's knowledge, keeping payments (£50-£200 per matter) for himself, failing to confirm fees in writing, keep accounting records, register as a Recognised Sole Practitioner, or hold professional indemnity insurance. He admitted all allegations, including dishonesty. The Tribunal approved an agreed outcome, finding no exceptional circumstances and, per SRA v Sharma, struck him off the Roll and ordered £5,000 costs.
Duties found breached:
- Act in the client's best interests
- Non-discriminatory acceptance and cab-rank
- No conflict between current clients
- Not misrepresent regulated status
Aggravating factors:
- Acted dishonestly
- Misconduct was deliberate, planned and repeated over almost 3 years
- Concealed his actions from his employers
- Knew his conduct was in material breach of his obligations
- Breached the trust placed in him by his employers
- Very high culpability, motivated to earn fees for himself
Mitigating factors:
- Nearly 20 years of previously unblemished record
- Repaid the total sum of £8,400 to GLC
- Full and frank admissions
- Clients were aware of the basis of representation and largely satisfied
- Genuine need among clients no longer eligible for Legal Aid
- Dismissal had profound effect on him and his family
Duties engaged
- Honesty
- No bribery or improper gifts
- Personal probity and fitness to practise
- Uphold public trust in the profession
- No unlawful discrimination or harassment
- Act in the client's best interests
- Advise objectively, not a mere conduit
- Non-discriminatory acceptance and cab-rank
- No conflict between current clients
- Prompt accounting and return of money
- Accounting records, reconciliation and reports
- Not misrepresent regulated status