Skip to main content
discipline 3 October 2026

The duty in context

Not mislead the court court

The lawyer must not knowingly or recklessly mislead or attempt to mislead the court (or permit it to be misled), and must promptly correct any misleading statement once aware of it.

380 cases 54% strike-off avg suspension 14.7 mo avg fine 55,578 121 with dishonesty finding

How the codes express this duty

E&W Solicitors SRA Principles & Code CCS 1.4; CCS 2.4 strong 246 cases
1.4 You do not mislead or attempt to mislead your clients, the court or others, either by your own acts or omissions or allowing or being complicit in the acts or omissions of others (including your client). 2.4 You only make assertions or put forward statements, representations or submissions to the court or others which are properly arguable.
E&W Barristers BSB Handbook rC3.1; rC6; gC4 strong 17 cases
rC3.1 you must not knowingly or recklessly mislead or attempt to mislead the court; rC6 Your duty not to mislead the court will include the following obligations: .1 you must not: .a make submissions, representations or any other statement; or .b ask questions which suggest facts to witnesses which you know, or are instructed, are untrue or misleading. gC4 ... knowingly misleading the court also includes inadvertently misleading the court if you later realise that you have misled the court, and you fail to correct the position.
Cayman Islands Legal Services Code 2026 R.2.1(a); R.2.4 strong
not knowingly or recklessly mislead or attempt to mislead the Court or permit the Court to be misled (R.2.4 applies)
AU Solicitors Solicitors' Conduct Rules Rules 19.1; 19.2 strong 77 cases
19.1 A solicitor must not deceive or knowingly or recklessly mislead the court. 19.2 A solicitor must take all necessary steps to correct any misleading statement made by the solicitor to a court as soon as possible after the solicitor becomes aware that the statement was misleading.
AU Barristers Uniform Barristers Rules rr26-27 strong 29 cases
A barrister must not deceive or knowingly or recklessly mislead the Court. A barrister must take all necessary steps to correct any misleading statement made by the barrister to a court as soon as possible after the barrister becomes aware that the statement was misleading.
IE Solicitors Law Society Guide Ch5 — General; Ch5 — The advocate / conducting litigation strong 3 cases
should assist the court in the administration of justice, and should not deceive, or knowingly or recklessly, mislead the court... A solicitor should not assert what they know to be untrue or substantiate a fraud, as that would amount to a positive deception of the court.
IE Barristers Bar Code of Conduct Rule 5.16; Rule 5.3(e) strong 3 cases
Barristers must not deceive or knowingly mislead the court. A Barrister must take appropriate steps to correct any misleading statement made by the Barrister to the court as soon as possible after the Barrister becomes aware that the statement was misleading.
JM Attorneys Canons of Professional Ethics Canon V(o); Canon VI(cc); Canon IV(q)(ii) strong 8 cases
(o) An Attorney shall not knowingly make a false statement of law or fact. ... (cc) An Attorney shall not knowingly represent falsely to a Judge, a Court or other tribunal or an official of a Court, or other tribunal, that a particular state of facts exists.
JE Lawyers Law Society of Jersey Code R.3.1 a); R.3.4 strong
Members must: a) not knowingly or recklessly mislead or attempt to mislead the court or permit the court to be misled (R.3.4 applies)... Members must not: a) make submissions, representations or any other statement, or b) register, file or otherwise lodge any documents with the court, Judicial Greffe or Viscount, that they know, or are instructed, are untrue or misleading.
ON Lawyers LSO Rules of Prof. Conduct r 5.1-2(e) strong
When acting as an advocate, a lawyer shall not ... knowingly attempt to deceive a tribunal or influence the course of justice by offering false evidence, misstating facts or law, presenting or relying upon a false or deceptive affidavit, suppressing what ought to be disclosed, or otherwise assisting in any fraud, crime, or illegal conduct
BC Lawyers BC Code r 5.1-2(e) strong 7 cases
When acting as an advocate, a lawyer must not: ... (e) knowingly attempt to deceive a tribunal or influence the course of justice by offering false evidence, misstating facts or law, presenting or relying upon a false or deceptive affidavit, suppressing what ought to be disclosed or otherwise assisting in any fraud, crime or illegal conduct;
NZ Lawyers Conduct & Client Care Rules r 13.1 strong
A lawyer has an absolute duty of honesty to the court and must not mislead or deceive the court.
SCO Solicitors LSS Standards of Conduct B1.13 strong 8 cases
You must never knowingly give false or misleading information to the court.
SG Lawyers Professional Conduct Rules 2015 r 9 (Conduct of proceedings) partial 6 cases
9 Conduct of proceedings
HK Solicitors Solicitors' Guide Principle 10.03 strong
A solicitor must never knowingly attempt to deceive or participate in the deception of a court. ... He must not, however, himself knowingly put forward or let his client put forward false information with intent to mislead the court.
HK Barristers Bar Code of Conduct para 10.30 strong
A practising barrister must not knowingly deceive or mislead the Court.

Cases dealing with this duty

Clear

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

  • Stormer, Terence William
    OLSC solicitor Stormer Lawyers [2010] NSWADT 240 2011-01-18 found breached

    1. Breach of Section 61 of the Legal Profession Act 1987 - handling of trust moneys 2. Breach of Section 62 of the Legal Profession Act 1987 - keeping of trust accounts 3. Attempting to mislead client 4. Failing to acco…

    Costs Removal of practitioner's name from the Roll of Local Lawyers (18/01/2011 Disciplinary Action) $0.00 Proceedings Instituted 2 PDFs View decision
  • Andrew John Field
    SDT solicitor 10700/2011 2011-01-01 text match

    Breaches, Failures

    Strike off 1 PDF View decision
  • David Juler Hawker
    SDT solicitor 10728/2011 2011-01-01 found breached

    Breaches, Failures

    Suspend - Indefinite 1 PDF View decision
  • Godwin Nwankwo Ijomanta
    SDT solicitor 10824/2011 2011-01-01 found breached

    Breaches, Failures, Others

    Strike off 1 PDF View decision
  • Newford E Shillingford & Another
    SDT solicitor 10714/2011 2011-01-01 found breached

    Breaches, Client Money, Failures, Others

    Fine, Suspend - Indefinite 1 PDF View decision
  • Kengai Ponnampalam Chetty
    SDT solicitor 10761/2011 2011-01-01 text match

    Breaches, Criminal Convictions

    Strike off 1 PDF View decision
  • Anthony Thomas Bryson
    SDT solicitor 10849/2011 2011-01-01 found breached

    Breaches, Failures

    Suspend - Indefinite 1 PDF View decision
  • MARTIN LEE SEGLER
    LPBWA lawyer 572 Hay Street PERTH WA 6000 Legal Profession Complaints Committee v Segler [2010] WASAT 135 and [2010] WASAT 135 (S) 2010-09-30 found breached text match

    Professional Misconduct and Unsatisfactory Professional Conduct and Suspended

    Professional Misconduct and Unsatisfactory Professional Conduct and Suspended 2 PDFs View decision
  • O'donnell, John Alexander
    OLSC solicitor (Formerly) John A O'Donnell & Associates [2010] NSWADT 130 2010-05-31 found breached

    1. Wilfully breached Sections 255 and 264 of Legal Profession Act 2004 - relating to trust funds 2. Wilfully breached Section 264 of the Legal Profession Act 2004 - handling of trust moneys 3. Misappropriated funds 4. F…

    Costs Removal of practitioner's name from the Roll of Local Lawyers $0.00 Proceedings Instituted 1 PDF View decision
  • Truong, Mai
    OLSC solicitor Mai Lawyers 2010-04-15 text match

    Misleading the Local Court at Burwood on 1 October 2008 — A reasonable likelihood of a finding of unsatisfactory professional conduct

    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
  • Karon Brown
    SDT solicitor 10413/2010 2010-01-01 found breached

    Breaches, Failures, Others

    Strike off 1 PDF View decision
  • Deborah Beyioku & Others
    SDT solicitor 10416/2010 2010-01-01 found breached

    Breaches, Client Money, Delays, Failures, Solicitors' Accounts Rules, Others

    No Order, Reprimand, S.43 Order (clerks) 1 PDF View decision
  • John Gregory Hardman
    SDT solicitor 10589/2010 2010-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules, Others

    Strike off 1 PDF View decision
  • Stuart Gemmell McPhail & Another
    SDT solicitor 10624/2010 2010-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules, Others

    Reprimand, Strike off 1 PDF View decision
  • Aygun Sahin
    SDT solicitor 10641/2010 2010-01-01 found breached

    Breaches, Client Money

    Strike off 1 PDF View decision
  • A Kyriacou - Y Mohammed
    SDT solicitor 10517/2010 2010-01-01 found breached text match

    Breaches, Criminal Convictions, Failures, Solicitors' Accounts Rules, Others

    S.43 Order (clerks), Suspend - Fixed Period 1 PDF View decision
  • Simon John Holborn
    SDT solicitor 10672/2010 2010-01-01 found breached

    Breaches, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Endy Okoye & David Laryea
    SDT solicitor 10497/2010 2010-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules, Others

    Strike off 1 PDF View decision
  • Peter James Scott
    SDT solicitor 10551/2010 2010-01-01 found breached

    Breaches, Client Money, Failures, Others, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Doherty, Peter John
    OLSC solicitor (Formerly) Lloyd Lancaster Pty Ltd [2009] NSWADT 296 2009-11-30 found breached

    1. Breach Section 255 of the Legal Profession Act 2004 - holding, disbursing and accounting for trust money 2. Misappropriation of trust monies 3. Knowingly mislead the client 4. Unreasonable delay 5. Failure to account…

    Additional Orders made by the Tribunal (see Tribunal decision) Conditions on Practising Certificate Costs Cancellation of practising certificate from 25 September 2009 to 25 September 2010 $0.00 Appeal Status: Dismissed Appeal Decision View decision
  • Holt, Michael Francis
    OLSC solicitor Holt & Allen [2009] NSWADT 163 2009-06-26 found breached

    1. Misled or attempted to mislead officer of State Revenue and Trust Account Inspectors 2. Failure to account 3. False stamping of documents in attempt to defraud the Office of State Revenue 4. Misappropriation 5. Negli…

    Costs Removal of practitioner's name from the Roll of Local Lawyers $0.00 Proceedings Instituted 1 PDF View decision
  • WILLFRIED VOGT
    LPBWA lawyer PO Box 102 NORTHBRIDGE WA 6865 Legal Practitioners Complaints Committee v Vogt [2009] WASAT Vogt v Legal Profession Complaints Committee [2009] WASCA 2009-05-22 found breached text match

    Unsatisfactory Conduct by Unprofessional Conduct and Suspended

    Unsatisfactory Conduct by Unprofessional Conduct and Suspended 2 PDFs View decision
  • Marshall, Roger David
    OLSC barrister Ground Floor Wentworth Chambers 2009-05-14 text match

    Misled Associate Judge Harrison in proceedings in the Supreme Court — A reasonable likelihood of a finding of unsatisfactory professional conduct

    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
  • Lanza L. Turner-Bowen
    GLC attorney 176 of 2006 2009-04-09 rule cited

    Acquitted | Disciplinary Committee decision delivered April 09, 2009. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCILCOMPLAINT No. 176/2006 BETWEEN SAMEER YOUNIS COMPLAINANT AND LANZA TURNER…

    Acquitted 1 PDF View decision
  • Jeremy Stuart Gordon Donaldson
    LSBC lawyer 2009-04-02 found breached

    Agreed Statement of Facts

    Agreed Statement of Facts 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.