Skip to main content
discipline 1 October 2026

The duty in context

Honour professional undertakings profession

The lawyer is personally bound to honour and perform within the agreed or a reasonable time any undertaking given, and must not give an undertaking they cannot fulfil or use one as an improper inducement.

450 cases 55% strike-off avg suspension 13.1 mo avg fine 77,603 105 with dishonesty finding

How the codes express this duty

E&W Solicitors SRA Principles & Code CCS 1.3 strong 224 cases
1.3 You perform all undertakings given by you, and do so within an agreed timescale or if no timescale has been agreed then within a reasonable amount of time.
E&W Barristers BSB Handbook rC11; gC33 partial 1 case
rC11 You must within an agreed timescale or within a reasonable period of time comply with any undertaking you give in the course of conducting litigation.
Cayman Islands Legal Services Code 2026 R.11.4 strong
An attorney-at-law who has given a personal undertaking to another attorney-at-law or a recognised law entity in the course of practice is personally bound by that undertaking, shall honour that undertaking and shall ensure that it is performed in a timely and effective manner, unless the attorney-at-law is clearly and unequivocally released by the recipient or the Court.
AU Solicitors Solicitors' Conduct Rules Rule 6.1 strong 92 cases
A solicitor who has given an undertaking in the course of legal practice must honour that undertaking and ensure the timely and effective performance of the undertaking, unless released by the recipient or by a court of competent jurisdiction.
AU Barristers Uniform Barristers Rules no clear equivalent
IE Solicitors Law Society Guide Ch6 — Undertakings: General; General guidance on undertakings strong 84 cases
A solicitor is required to honour the terms of an undertaking as a matter of professional conduct. A breach of an undertaking is a matter of professional misconduct... An undertaking should not be given by a solicitor as an inducement to a client to secure that client's business... A solicitor who gives an undertaking that is expressed to be dependent upon the happening of a future event should notify the recipient promptly if it becomes clear that the event will not occur.
IE Barristers Bar Code of Conduct no clear equivalent
JM Attorneys Canons of Professional Ethics Canon VI(c); Canon VI(d); Canon VI(e) strong 25 cases
(c) An Attorney shall not commit a breach of an undertaking given by him to a Judge, a Court or other tribunal or an official thereof ... (d) An Attorney shall not give a professional undertaking which he cannot fulfil and shall fulfil every such undertaking which he gives.
JE Lawyers Law Society of Jersey Code R.10.4 strong
A member who has given, or whose employee has given, an undertaking to another member or the firm of another member in the course of practice is personally bound by that undertaking and must honour that undertaking and ensure that it is performed in a timely and effective manner.
ON Lawyers LSO Rules of Prof. Conduct r 7.2-11; r 5.1-6 strong
7.2-11 A lawyer shall not give an undertaking that cannot be fulfilled and shall fulfill every undertaking given and honour every trust condition once accepted. [5.1-6: A lawyer must strictly and scrupulously fulfill any undertakings given by him or her and honour any trust conditions accepted in the course of litigation.]
BC Lawyers BC Code r 7.2-11 strong 7 cases
A lawyer must: (a) not give an undertaking that cannot be fulfilled; (b) fulfill every undertaking given; and (c) honour every trust condition once accepted.
NZ Lawyers Conduct & Client Care Rules r 10.5 strong
A lawyer must honour all undertakings, whether written or oral, that the lawyer gives to any person in the course of practice.
SCO Solicitors LSS Standards of Conduct B1.14 partial 8 cases
You must act with other regulated persons in a manner consistent with persons having mutual trust and confidence in each other.
SG Lawyers Professional Conduct Rules 2015 r 7 (Responsibilities of legal practitioners to each other) partial 6 cases
7 Responsibilities of legal practitioners to each other
HK Solicitors Solicitors' Guide Principle 14.02 / Principle 14.01 strong
A solicitor must honour the terms of a professional undertaking. ... An undertaking shall only be given by a solicitor and is binding upon him personally, and if given in the course of practice, also binds his firm. ... an undertaking should never be given unless the solicitor giving it is certain that he personally can comply with it.
HK Barristers Bar Code of Conduct para 10.4 strong
A practising barrister, while engaging in practice, must not give any undertaking that cannot be fulfilled and must fulfil every undertaking that has been given by him.

Cases dealing with this duty

Clear

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

  • Michael Saul Menkes
    LSBC lawyer 2026-06-05 text match

    Rule 3-7.1 Consent Agreement

    Rule 3-7.1 Consent Agreement 1 PDF View decision
  • Maame Adjoa Djan-Krofa
    SDT solicitor 12771/2025 2026-04-30 found breached rule cited

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

    Suspended period of Suspension 1 PDF View decision
  • (unnamed)
    SDT solicitor 12853/2025 2026-03-13 text match
    Restoration to the Roll - Refused 1 PDF View decision
  • Shafiq-ul Hassan
    SDT solicitor 12567/2024 2026-03-12 found breached

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

    Suspend - Fixed Period 1 PDF View decision
  • Antoneita Alicia Hall
    GLC attorney 177 of 2024 2026-02-28 found breached text match

    Suspended | Disciplinary Committee decision delivered February 28, 2026. || Guilty of Misconduct in a Professional Respect | Disciplinary Committee decision delivered November 22, 2025. View PDF SANCTION DECISION OF THE…

    Suspended 2 PDFs View decision
  • Phillip David Gallasch
    LPCC-SA lawyer 100 Philip Highway, Elizabeth SA 5112 2026-02-25 found breached

    The Practitioner was the victim of a third-party cyber fraud which resulted in the loss of $149,588.28 of his client’s money. The Practitioner failed to verify the banking details received by email with his client by te…

    Reprimand View decision
  • Antoneita Alicia Hall
    GLC attorney 177 of 2024 2025-11-22 text match

    Guilty of Misconduct in a Professional Respect | Disciplinary Committee decision delivered November 22, 2025. || Suspended | Disciplinary Committee decision delivered February 28, 2026. View PDF DECISION OF THE DISCIPLI…

    Guilty of Misconduct in a Professional Respect 1 PDF View decision
  • (unnamed)
    SDT solicitor 12745/2025 2025-10-06 text match

    Client Money, Code of Conduct 2007, Code of Conduct 2011, Solicitors Accounts Rules 2011, SRA Principles 2011

    Variation of Conditions on Practising Certificate 1 PDF View decision
  • Mitchell Cavanagh
    LSC-QLD solicitor Non-practising firm 2025-08-19 found breached rule cited

    The conduct identified in charge 1 is proved and is found to constitute professional misconduct.

    Fined 1 PDF View decision
  • Charles Michael Stevens
    SDT solicitor 12691/2024 2025-07-03 found breached text match

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

    Strike off 1 PDF View decision
  • Imran Haider Khawaja
    SDT solicitor 12681/2024 2025-06-19 text match

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

    Fine 1 PDF View decision
  • Ano Maggielin Miller Sewell
    GLC attorney 117 of 2024 2025-05-31 rule cited

    Guilty | Disciplinary Committee decision delivered May 31, 2025. || Struck off, Restitution Ordered | Disciplinary Committee decision delivered June 27, 2025. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENER…

    Guilty 1 PDF View decision
  • (unnamed)
    SDT solicitor 12672/2024 2025-04-26 rule cited

    Appeals

    S.44E/ S.46/Paragraph 14C Appeals 1 PDF View decision
  • Robin Edward Stubbings
    SDT solicitor 12641/2024 2025-03-21 found breached rule cited

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

    Fine 1 PDF View decision
  • Kerr Clement
    SDT solicitor 12661/2024 2025-03-14 found breached text match

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

    Fine 1 PDF View decision
  • Respondent AM
    SDT solicitor 12645/2024 2025-03-14 found breached

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

    Suspend - Fixed Period 1 PDF View decision
  • John Mark Fitzpatrick
    LPCC-SA lawyer Unit 1, 121 Walkerville Terrace, Walkerville SA 5081 2025-03-07 found breached text match

    Repeated failures and breaches of Rules relating to the conduct of legal practitioners, including, repeated failures to respond in an adequate and timely manner to requests for information from the Commissioner and the …

    Struck off View decision
  • Steven George Powell
    GLC attorney 176 of 2022 2024-11-28 rule cited

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered November 28, 2024. || Disciplinary Committee decision delivered May 13, 2025. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL …

    Guilty of Professional Misconduct 1 PDF View decision
  • Simon Paget-Brown
    SDT solicitor 12551/2024 2024-09-13 found breached text match

    Breaches, Code of Conduct 2011, Code of Conduct for Solicitors, REL's & RFL's 2019, Failures, Solicitors Accounts Rules 1998, Solicitors Accounts Rules 2019, SRA Principles 2011, SRA Principles 2019

    Suspend - Fixed Period 1 PDF View decision
  • Martin Darren Rounthwaite
    SDT solicitor 12530/2023 2024-09-13 found breached

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

    Strike off 1 PDF View decision
  • Darryl Richards
    LSC-QLD solicitor Certus Legal Pty Ltd 2024-09-03 found breached rule cited

    Guilty of professional misconduct

    Suspended 1 PDF View decision
  • Nedumaran Muthukrishnan
    SG-DT lawyer M Nedumaran & Co 2024-07-04 rule cited
    Suspended for a period of four (4) years 1 PDF View decision
  • Seah Choon Huat Johnny
    SG-DT lawyer Seah & Co 2024-07-01 rule cited
    Suspended for a period of four (4) years 1 PDF View decision
  • (unnamed)
    SDT solicitor 12537/2024 2024-06-28 found breached
    Restoration to the Roll - Refused 1 PDF View decision
  • Hughes, Owen Maldwyn
    OLSC solicitor (Formerly) Beesley and Hughes 2024-06-27 found breached text match

    Failure to disclose AHRC sexual harassment complaint to the Law Society in his practising certificate renewal application Failure to disclose sexual harassment proceedings to the Law Society in his practising certificat…

    Refusal of grant of practising certificate for the year ending 30 June 2024 $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

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.