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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 Paterson Penman
    SSDT solicitor Andrew Paterson Penman, 68 Orchard Terrace, Hawick 2022-02-18 found breached
    strike_off No Appeal 1 PDF View decision
  • Rosario Cateno Di Bella
    LSBC lawyer 2022-01-27 found breached

    Rule 4-29 Admission of Misconduct and Undertaking to the Discipline Committee

    Rule 4-29 Admission of Misconduct and Undertaking to the Discipline Committee 1 PDF View decision
  • Martin Grahame Hogg
    SSDT solicitor Martin Grahame Hogg, residing at 39 Kingshill Avenue, Cumbernauld 2022-01-26 found breached
    reprimand No Appeal 1 PDF View decision
  • George Edward Nosworthy
    SDT solicitor 12356/2022 2022-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Tanya Latoya Walters Powell
    GLC attorney 176 of 2018 2021-12-03 found breached

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered December 3, 2021. ||Restitution ordered, Fined | Disciplinary Committee decision delivered March 09, 2022 View PDF DECISION OF THE DISCIPLINA…

    Guilty of Professional Misconduct 4 PDFs View decision
  • Amarjit Singh Dhindsa
    LSBC lawyer 2021-12-02 found breached

    Rule 4-29 Admission of Misconduct and Undertaking to the Discipline Committee

    Rule 4-29 Admission of Misconduct and Undertaking to the Discipline Committee 1 PDF View decision
  • Hughes, Owen Maldwyn
    OLSC solicitor Beesley & Hughes 2021-11-24 found breached

    Allegation 1 - The Lawyer engaged in sexual harassment and / or workplace bullying in breach of Rule 42 of the Legal Profession Uniform Law Australian Solicitors’ Conduct Rules 2015 (“the Solicitors’ Rules”) Further, or…

    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
  • Sean O’Neil Kinghorn
    GLC attorney 190 of 2020 2021-11-16 found breached

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered November 16, 2021 || Fined | Disciplinary Committee decision delivered April 13, 2022 || Formal Order delivered April 19, 2022 (PDF) View PDF…

    Guilty of Professional Misconduct 2 PDFs View decision
  • Martin Doyle
    LSC-QLD solicitor 2021-11-09 found breached

    The respondent engaged in professional misconduct.

    Struck off 1 PDF View decision
  • Harold C. Brady
    GLC attorney 1 of 2017 2021-11-05 found breached

    Appeal for Stay of Execution Refused | Court of Appeal decision delivered November 05, 2021. View PDF in Full Screen [2021] JMCA App 27 JAMAICA IN THE COURT OF APPEAL BEFORE: THE HON MRS JUSTICE MCDONALD-BISHOP JA THE H…

    Appeal for Stay of Execution Refused 1 PDF View decision
  • Seymour George Stewart
    GLC attorney 78 of 2020 2021-11-03 found breached

    Fined | Disciplinary Committee decision delivered November 03, 2021. || Guilty of Professional Misconduct | Disciplinary Committee decision delivered July 26, 2021. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE…

    Fined 1 PDF View decision
  • Stephen McGuire
    SSDT solicitor Stephen McGuire, Hennessey Bowie & Co., 2 Kenmure Lane, Bishopbriggs 2021-10-28 found breached
    fine No Appeal 1 PDF View decision
  • KELVIN KA CHUEN TANG
    LPBWA lawyer Suite 2 191 James Street NORTHBRIDGE WA, 6003 Legal Profession Complaints Committee v Tang [2021] WASAT 2021-09-03 found breached

    Professional Misconduct

    Professional Misconduct 1 PDF View decision
  • Youssef, Nidah
    OLSC solicitor NY Lawyers Pty Ltd 2021-08-19 found breached

    From 3 July 2018 to 3 September 2018 the respondent solicitor engaged in legal practice in New South Wales without holding a practising certificate. The respondent solicitor attempted to mislead the Law Society of New S…

    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
  • Kernaghan, Aaron Noel
    OLSC solicitor Kernaghan & Associates Pty Ltd [2021] NSWCATOD 111 2021-08-06 found breached

    Professional Misconduct Breached an undertaking to the Office of the Legal Services Commissioner Breach section 137 of the Legal Profession Uniform Law (NSW) - Certain trust money to be deposited in general trust accoun…

    To be determined by the Tribunal $0.00 1 PDF View decision
  • Dwight St. George Reece
    GLC attorney 168 of 2020 2021-07-30 found breached

    Appeal dismissed, GLC Disciplinary Committee Decision Affirmed | Court of Appeal decision delivered July 30, 2021. View PDF [2021] JMCA Misc 1 JAMAICA IN THE COURT OF APPEAL BEFORE: THE HON MR JUSTICE F WILLIAMS JA THE …

    Appeal dismissed, GLC Disciplinary Committee Decision Affirmed 1 PDF View decision
  • Clifton, David Vincent
    OLSC solicitor Clifton Legal [2021] NSWCATOD 101 2021-07-27 found breached

    Breach of section 138(1)(b) of the Legal Profession Uniform Law - Holding, disbursing and accounting for trust money in general trust account Breach of section 148 of the Legal Profession Uniform Law - Deficiency in tru…

    Costs Order recommending removal of lawyer's name from the Roll of Australian Lawyers On 10 December 2021, NSW Supreme Court Court of Appeal ordered: 1. The name of the respondent David Vincent Clifton be removed from the roll kept by the Supreme Court of New South Wales. (2) The respondent pay the applicant’s costs. $0.00 Disciplinary Action 2 PDFs View decision
  • Seymour George Stewart
    GLC attorney 78 of 2020 2021-07-26 found breached

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered July 26, 2021. || Fined | Disciplinary Committee decision delivered November 03, 2021. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE…

    Guilty of Professional Misconduct 1 PDF View decision
  • Elina, Hermansah Herman
    OLSC solicitor GNB Lawyers [2021] NSWCATOD 98 2021-07-20 found breached

    Contravened section 137 of the Legal Profession Uniform Law (NSW) Mixed trust money with other money in contravention of section 146 of the Legal Profession Uniform Law (NSW) Made false declarations in the annual Law Pr…

    Costs Practitioner to undertake and complete further legal education Reprimand $0.00 1 PDF View decision
  • Kenneth John Baillie Stewart Macleod
    SSDT solicitor Kenneth John Baillie Stewart MacLeod, MacLeods WS, 13 Lombard Street, Inverness 2021-07-01 found breached
    strike_off No Appeal 2 PDFs View decision
  • Mohammed Uddin
    BTAS barrister Lincoln's Inn 2021-06-30 found breached
    Final 2 PDFs View decision
  • Jacqueline Marie Minto
    GLC attorney 138 of 2020 2021-06-19 found breached

    Fined | Disciplinary Committee decision delivered June 19, 2021. || RESULT: Guilty of Professional Misconduct, Fined | Disciplinary Committee decision delivered June 19, 2021. View PDF FORMAL ORDER OF THE DISCIPLINARY C…

    Fined 1 PDF View decision
  • (unnamed)
    SSDT solicitor 2021-06-11 found breached
    dismissed No Appeal 4 PDFs View decision
  • Kevin Manning
    BTAS barrister Middle Temple 2021-06-10 found breached
    strike_off Final 2 PDFs View decision
  • W. Anthony Pearson
    GLC attorney 18 of 2018 2021-06-04 found breached

    Fined | Disciplinary Committee decision delivered June 04, 2021. || Guilty of Misconduct in a Professional Respect | Disciplinary Committee decision delivered April 24, 2021. View PDF FORMAL ORDER OF THE DISCIPLINARY CO…

    Fined 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.