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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

  • Zeeshan Saqib Mian
    SDT solicitor 12824/2025 2026-09-07 found breached

    Breaches, Dishonesty, Lack of Integrity, Recklessness, SRA Principles 2011

    Strike off 1 PDF View decision
  • Gordon Mcpherson Keir
    SDT solicitor 12807/2025 2026-08-25 found breached

    Account Rules breaches, Breaches, Code of Conduct for Firms 2019, Code of Conduct for Solicitors, REL's & RFL's 2019, Dishonesty, Lack of Integrity, Solicitors Accounts Rules 2011, Solicitors Accounts Rules 2019, SRA Pr…

    Reprimand 1 PDF View decision
  • (unnamed)
    SDT solicitor 12929/2026 2026-08-25 found breached
    S.44E/ S.46/Paragraph 14C Appeals 1 PDF View decision
  • Kieran Ferguson
    SDT solicitor 12863/2025 2026-08-18 found breached

    Breaches, Code of Conduct for Solicitors, REL's & RFL's 2019, Dishonesty, Lack of Integrity, SRA Principles 2019

    Strike off 1 PDF View decision
  • Matthew Moss
    SDT solicitor 12910/2026 2026-08-18 found breached

    Breaches, Code of Conduct for Solicitors, REL's & RFL's 2019, Dishonesty, Lack of Integrity, SRA Principles 2019

    Strike off 1 PDF View decision
  • Julian Condliffe
    SDT solicitor 12689/2024 2026-08-05 found breached

    Breaches, Code of Conduct 2011, Code of Conduct for Firms 2019, Code of Conduct for Solicitors, REL's & RFL's 2019, Dishonesty, Lack of Integrity, Solicitors Accounts Rules 2019, SRA Principles 2011, SRA Principles 2019

    Strike off 1 PDF View decision
  • Elizabeth Forrest
    SDT solicitor 12838/2025 2026-08-05 found breached

    Breaches, Code of Conduct 2011, Code of Conduct for Solicitors, REL's & RFL's 2019, Lack of Integrity, SRA Principles 2011, SRA Principles 2019

    Suspend - Fixed Period 1 PDF View decision
  • Richard Jefferies
    SDT solicitor 12846/2025 2026-07-21 found breached

    Authorisation of Individuals Regulations 2019, Breaches, Code of Conduct for Solicitors, REL's & RFL's 2019, Dishonesty, Lack of Integrity, Solicitors Accounts Rules 2019, SRA Principles 2019

    Strike off 1 PDF View decision
  • Habibur Choudhury; Archstone Solicitors Limited
    SDT solicitor 12852/2025 2026-06-15 found breached

    Code of Conduct for Firms 2019

    Fine 1 PDF View decision
  • Paul Ignatius Boylan
    LPCC-SA lawyer 138 Florence Street, Port Pirie SA 5540 2026-06-10 found breached

    In 2018, the Practitioner breached his fundamental duties to act in his client’s best interests in breach of ASCR 4.1.1 and failed to avoid any compromise to his integrity and professional independence in breach of ASCR…

    Multiple Disciplinary Action Fine Reprimand View decision
  • Mark Grenville Davies
    SDT solicitor 12796/2025 2026-06-09 found breached

    Code of Conduct 2011, Code of Conduct for Solicitors, REL's & RFL's 2019, Dishonesty, Solicitors Accounts Rules 2011, Solicitors Accounts Rules 2019, SRA Principles 2011, SRA Principles 2019

    Strike off 1 PDF View decision
  • Sarinjit Singh Bahia
    SDT solicitor 12574/2024 2026-06-09 found breached

    Account Rules breaches, Code of Conduct 2011, Code of Conduct for Solicitors, REL's & RFL's 2019, Dishonesty, Lack of Integrity, Misappropriation of Client Account, Solicitors Accounts Rules 2019, SRA Principles 2011, S…

    Fine 1 PDF View decision
  • Michael Saul Menkes
    LSBC lawyer 2026-06-05 found breached

    Rule 3-7.1 Consent Agreement

    Rule 3-7.1 Consent Agreement 1 PDF View decision
  • Darren Shaw
    SDT solicitor 12804/2025 2026-05-28 found breached

    Solicitors Act 1974

    S.43 Order (clerks) 1 PDF View decision
  • Louisa Frances Clapton
    SDT solicitor 12873/2025 2026-05-19 found breached

    Breaches, Code of Conduct for Solicitors, REL's & RFL's 2019, Dishonesty, SRA Principles 2019

    Strike off 1 PDF View decision
  • Robert Mannering Sedgwick
    SDT solicitor 12806/2025 2026-05-12 found breached

    Breaches, Code of Conduct 2011, SRA Principles 2011, SRA Principles 2019

    Strike off 1 PDF View decision
  • Nicole Tam
    LSBC lawyer 2026-05-08 found breached

    Rule 3-7.1 Consent Agreement

    Rule 3-7.1 Consent Agreement 1 PDF View decision
  • Alexander William Bruce Lee
    SDT solicitor 12813/2025 2026-04-28 found breached

    Breaches, Code of Conduct 2011, SRA Principles 2011

    Fine 1 PDF View decision
  • Darren Paul Kruse
    LPCC-SA lawyer 20 Coromandel Parade, Blackwood SA 5051 2026-04-24 found breached

    Between December 2020 and March 2021, the Practitioner failed to act on client instructions and respond to client correspondence, in breach of the following South Australian Legal Practitioners Conduct Rules: • to act i…

    Multiple Disciplinary Action Fine Order to apologise Reprimand View decision
  • Darren Paul Kruse
    LPCC-SA lawyer 20 Coromandel Parade, Blackwood SA 5051 2026-04-24 found breached

    Between August 2021 and November 2021, the Practitioner failed to act on client instructions and respond to client correspondence, in breach of the following South Australian Legal Practitioners Conduct Rules: • to act …

    Multiple Disciplinary Action Fine Order to apologise Reprimand View decision
  • (unnamed)
    SDT solicitor 12878/2025 2026-04-15 found breached
    Variation of Conditions on Practising Certificate 1 PDF View decision
  • Clare Elizabeth Forster
    SDT solicitor 12752/2025 2026-04-13 found breached

    Code of Conduct for Solicitors, REL's & RFL's 2019, SRA Principles 2019

    Strike off 1 PDF View decision
  • Emma Smith
    BTAS barrister Lincoln's Inn 2026-04-08 found breached
    strike_off open to appeal 2 PDFs View decision
  • Rajesh Soni
    LSBC lawyer 2026-04-02 found breached

    Rule 4-29 Admission and Undertaking to the Discipline Committee

    Rule 4-29 Admission and Undertaking to the Discipline Committee 1 PDF View decision
  • Matthew Thomas Parish
    SDT solicitor 12748/2025 2026-03-24 found breached

    Breaches, Code of Conduct for Solicitors, REL's & RFL's 2019, SRA Overseas Principles, SRA Principles 2019

    Suspend - Fixed Period 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.