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discipline 30 September 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.

1,282 cases 61% strike-off avg suspension 17.6 mo avg fine 138,302 623 with dishonesty finding

How the codes express this duty

E&W Solicitors SRA Principles & Code CCS 6.2 strong 841 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 29 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 126 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 38 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 50 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 50 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 125 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 35 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 55 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 8 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

1,282 decisions · link basis: found breached = a tribunal finding; rule cited = the mapped provision is cited in the decision; text match = high-precision text pattern

  • James Edward Turner
    LSBC lawyer 2019-09-26 found breached

    Rule 4-29 Admission of Misconduct and Undertaking | Summary

    Rule 4-29 Admission of Misconduct and Undertaking | Summary 1 PDF View decision
  • Ms Vanessa Marie FARMER
    LSNT lawyer 22 Harry Chan Ave, Darwin NT 0800 NT Jurisdiction 2019-08-30 found breached

    Findings of professional misconduct Reasons for decision Reasons for penalty

    Public reprimand in respect of each charge Fine of $15,000 Complete further legal education in the areas of Ethics and Professional Responsibility and Practice Management, course not exceeding one day or equivalent online program Transfer trust money to the complainant within 7 days 2 PDFs View decision
  • Nagle, Peter Richard
    OLSC barrister 2019-08-15 found breached

    1. Engaged in legal practice in the period since 1 July 2016, contrary to section 10 of the Legal Profession Uniform Law 2. Represented himself as entitled to engage in legal practice in the period since 1 July 2016, co…

    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
  • Richard D. Bonner
    GLC attorney 151 of 2018 2019-07-27 found breached

    Fined, Reimbursement ordered | Disciplinary Committee decision delivered July 27, 2019. | Formal Order View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO: 151/2018 IN THE MATTER OF…

    Fined, Reimbursement ordered 2 PDFs View decision
  • Raymond Clough
    GLC attorney 186 of 2010 2019-07-26 found breached

    Suspended, Fined - Disciplinary Committee decision delivered July 26, 2019. | Guilty of Professional Misconduct - Disciplinary Committee decision May 11, 2019. | Formal Order July 26, 2019 View PDF DECISION OF THE DISCI…

    Suspended, Fined - Disciplinary Committee decision delivered July 26, 2019. 1 PDF View decision
  • Stuart, Andrew Graham
    OLSC solicitor Stuart & Mills [2019] NSWCATOD 108 2019-07-05 found breached

    1. Misappropriated trust funds 2. Breached section 255 LPA 2004 - Holding, disbursing and accounting for trust money 3. Breached section 263 LPA 2004 - Reporting certain irregularities and suspected irregularities 4. Br…

    Costs Removal of lawyer's name from the Roll of Local Lawyers $0.00 Proceedings Instituted 1 PDF View decision
  • Davidson, Chona Encarnacion Castillo
    OLSC solicitor Castillo Davidson & Associates [2019] NSWCATOD 105 2019-07-03 found breached

    Professional Misconduct 1. Misappropriation of trust funds 2. Breach of section 146 LPUL - Intermixing trust money 3. Breach section 138 LPUL - Holding trust money 4. Breach of section 148 LPUL - Deficiency in trust acc…

    Costs Issued with a restricted practising certificate (Disciplinary Action 30/06/2020) $0.00 Proceedings Instituted 2 PDFs View decision
  • Thadsanamorthy, Viji
    OLSC solicitor Viji Thadsan Solicitor [2019] NSWCATOD 96 2019-06-28 found breached

    Professional Misconduct 1. Breach of section 137 LPUL - Certain trust money to be deposited in general trust account 2. Breach of section 146 LPUL - Intermixing money 3. Misappropriation Unsatisfactory Professional Cond…

    Costs Fine Practitioner to undertake and complete further legal education Reprimand $5,000.00 Proceedings Instituted 1 PDF View decision
  • Keith A. Jarrett
    GLC attorney 42 of 2013 2019-06-27 found breached

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered June 27, 2019. || Suspended, Restitution Ordered | Disciplinary Committee decision delivered July 15, 2019. View PDF DECISION OF THE DISCIPLI…

    Guilty of Professional Misconduct 3 PDFs View decision
  • Gurusamy, Baskaran
    OLSC solicitor Gurusamy Lawyers [2019] NSWCATOD 89 2019-06-12 found breached

    1. Breached section 254 LPA - Certain trust money to be deposited in general trust account 2. Breached section 255 LPA - Trust money received in the form of cash 3. Breached section 260 LPA - Reporting certain irregular…

    Costs Fine Reprimand $5,000.00 Proceedings Instituted 1 PDF View decision
  • Howard A. Lettman
    GLC attorney 212 of 2017 2019-06-01 found breached

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered June 01, 2019 || Struck off | Disciplinary Committee decision delivered November 23, 2019 View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF …

    Guilty of Professional Misconduct 1 PDF View decision
  • Zhukovska, Myroslava
    OLSC solicitor McMahon Todd Pty Ltd [2019] NSWCATOD 66 2019-05-08 found breached

    Professional Misconduct 1. Acting in a conflict of interests 2. Failure to obtain instructions before making unsecured loan from client's funds 3. Charging excessive legal costs 4. Preferring own interests to those of c…

    Costs Fine Reprimand The lawyer's local practising certificate is cancelled and any new practising certificate shall not be issued before the end of 12 months from the date of these orders. $9,000.00 Proceedings Instituted 2 PDFs View decision
  • Donovan Occonor Malcolm
    GLC attorney 132 of 2017 2019-04-17 found breached

    Struck off, Restitution ordered | Disciplinary Committee decision delivered April 17, 2019. | Guilty of Professional Misconduct | Disciplinary Committee decision delivered March 08, 2019. View PDF DECISION OF THE DISCIP…

    Struck off, Restitution ordered 1 PDF View decision
  • Leslie Roy Campbell
    GLC attorney 62 of 2017 2019-03-26 found breached

    Reprimanded, Fined | Disciplinary Committee decision delivered March 26, 2019. View PDFs Decision Formal Order DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO: 62/2017 BETWEEN GEORGE ROB…

    Reprimanded, Fined 2 PDFs View decision
  • Lorraine Louise Ramson
    GLC attorney 234 of 2017 2019-03-23 found breached

    Guilty of Professional Misconduct, Restitution Ordered, Suspension | Disciplinary Committee decision delivered March 23, 2019. View PDF JUDGMENT OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL IN THE MATTER O…

    Guilty of Professional Misconduct, Restitution Ordered, Suspension 1 PDF View decision
  • Margaret Faith Rimmer
    LSC-QLD solicitor Maleny Law 2019-03-11 found breached

    Guilty of professional misconduct

    Struck off 1 PDF View decision
  • Melvi Poh Onn Tay
    LSC-QLD solicitor Tay Lawyers 2019-02-26 found breached

    Guilty of professional misconduct

    Struck off 1 PDF View decision
  • Yoon, Seog Won
    OLSC solicitor El Khan Legal [2019] NSWCATOD 28 2019-02-20 found breached

    1. Breached section 254 LPA 2004 - Certain trust money to be deposited in a general trust account 2. Breached section 255 LPA 2004 - Holding, disbursing and accounting for trust money 3. Breached section 260 LPA 2004 - …

    Costs Order recommending removal of lawyer's name from the Roll of Australian Lawyers $0.00 Proceedings Instituted 1 PDF View decision
  • Sean A. Clarke
    GLC attorney 14 of 2015 2019-01-26 found breached

    Guilty of Professional Misconduct, Restitution Ordered | Disciplinary Committee decision delivered January 26, 2019. Full Screen View View Decision View Formal Order JUDGMENT OF THE DISCIPLINARY COMMITTEE OF THE GENERAL…

    Guilty of Professional Misconduct, Restitution Ordered 2 PDFs View decision
  • Neil Frew
    BTAS barrister Middle Temple 2019-01-17 found breached
    strike_off Final 2 PDFs View decision
  • David Marriott
    SDT solicitor 11979/2019 2019-01-01 found breached

    Criminal Convictions

    Strike off 1 PDF View decision
  • Richard Stephen Davies
    SDT solicitor 11939/2019 2019-01-01 found breached

    Breaches, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Omer Mian
    SDT solicitor 11919/2019 2019-01-01 found breached

    Criminal Convictions

    S.43 Order (clerks) 1 PDF View decision
  • Eilish Adams
    SDT solicitor 12021/2019 2019-01-01 found breached

    Breaches, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Michael Usher
    SDT solicitor 12022/2019 2019-01-01 found breached

    Breaches, Failures

    Strike off 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.