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discipline 30 September 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

  • M A Olaseinde & A M Hemming
    SDT solicitor 9742/2007 2007-01-01 found breached

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

    Strike off, Suspend - Indefinite 1 PDF View decision
  • Omezie,Iban,Akinmoyo,Jasper,Orji & 2 Others
    SDT solicitor 9650 2007-01-01 found breached

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

    Fine, S.43 Order (clerks), Strike off, Suspend - Fixed Period 1 PDF View decision
  • Mark I Bronzite & Another
    SDT solicitor 9848/2007 2007-01-01 text match

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

    Strike off, Suspend - Fixed Period 1 PDF View decision
  • Brian Hargreaves-Hadcroft
    SDT solicitor 9677/2007 2007-01-01 found breached text match

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

    Strike off 1 PDF View decision
  • Douglas Laing MCCLELLAND
    LSC-QLD solicitor D L McClelland & Co 2006-11-24 found breached

    Guilty of professional misconduct on 1 charge Guilty of unsatisfactory professional conduct on 1 charge - except in respect of particular 2.2(b) which was not established

    other 1 PDF View decision
  • Rogers, Michael Peter Scott
    OLSC solicitor Michael Rogers & Co 2006-05-30 text match

    1. Failure to honour undertaking 2. Non-payment of Counsel's fees — 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
  • JOHN HENRY REYBURN
    LPBWA lawyer PO Box 231 MANDURAH WA 6210 VR 10 of 2004 2006-05-30 found breached

    Unprofessional Conduct

    Unprofessional Conduct 1 PDF View decision
  • Alan Monro Simpson
    SSDT solicitor Alan Monro Simpson, 48 Thomson Drive, Bearsden, Glasgow 2006-05-04 found breached
    strike_off No Appeal 1 PDF View decision
  • Pitsikas, Spero
    OLSC solicitor S Pitsikas & Associates [2006] NSWADT 102 2006-04-07 text match

    1. Failure to account for trust money in breach of Section 61 of the Legal Profession Act 1987 2. Failure to keep proper trust records in breach of Section 62 of the Legal Profession Act 1987 3. Wilful breaches of trust…

    Costs Removal of practitioner's name from the Roll of Local Lawyers $0.00 Proceedings Instituted 1 PDF View decision
  • Thomas Flood
    LSI solicitor 2 The Gap, Barndarrig, Co Wicklow 2006-03-06 text match

    THE HIGH COURT 2006 No 7 SA In the matter of Thomas Flood, solicitor, and in the matter of the Solicitors Acts 1954 to 2002 Law Society of Ireland (applicant) Thomas Flood (respondent solicitor) On 6 March 2006, the pre…

    strike_off View decision
  • Piper, Martin
    OLSC solicitor Budd & Piper [2006] NSWADT 12 2006-01-12 text match

    Failure to comply with undertaking — Unsatisfactory Professional Conduct

    Costs Fine Reprimand $1,000.00 Proceedings Instituted 1 PDF View decision
  • Kwaku Afrifa-Yamoah
    SDT solicitor 9609/2006 2006-01-01 found breached

    Failures

    Suspend - Indefinite 1 PDF View decision
  • Ali Brian Ferguson
    SDT solicitor 9463/2006 2006-01-01 found breached

    Others

    S.43 Order (clerks) 1 PDF View decision
  • Leon Daniel
    SDT solicitor 9493/2006 2006-01-01 found breached

    Failures, Others

    S.43 Order (clerks) 1 PDF View decision
  • 9623-2006 - James Donald Rory Anderson
    SDT solicitor 9623/2006 2006-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules, Others

    Strike off 1 PDF View decision
  • Ian Black
    SDT solicitor 9488/2006 2006-01-01 text match

    Delays, Failures

    Strike off 1 PDF View decision
  • Imran Karim, Saira Karim & Shamim Akktar Karim
    SDT solicitor 9450/2006 2006-01-01 found breached

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

    Strike off 1 PDF View decision
  • Stanley Sherwin Beller
    SDT solicitor 9630/2006 2006-01-01 found breached text match

    Failures

    Strike off 1 PDF View decision
  • Treanor, Laurence John
    OLSC solicitor Laurence J Treanor & Co [2005] NSWADT 285 2005-12-05 text match

    1. Failure to comply with Notices under Section 152 of the Legal Profession Act 1987 (x2) 2. Failure to honour undertakings — Professional Misconduct

    Costs Fine Reprimand $7,000.00 Proceedings Instituted 1 PDF View decision
  • Hinde, Jeffrey James
    OLSC solicitor Jeffrey Hinde & Associates [2005] NSWADT 199 2005-08-24 text match

    Failure to honour an Undertaking — Professional Misconduct

    Costs Fine Reprimand $3,000.00 Proceedings Instituted 1 PDF View decision
  • Mendigorin, Mario
    OLSC solicitor N/A [2005] NSWADT 185 2005-08-04 text match

    1. Breach of Section 61 Legal Profession Act, 1987 - handling of trust moneys 2. Breach of Section 62 Legal Profession Act, 1987- keeping of trust accounts 3. Failure to account (keep adequate records) 4. Breach of unde…

    Costs Removal of practitioner's name from the Roll of Local Lawyers The Law Society have leave to file in the Tribunal an agreed quantum of costs for purpose of enforcement $0.00 Proceedings Instituted 1 PDF View decision
  • JOHN HENRY REYBURN
    LPBWA lawyer PO Box 231 MANDURAH WA 6210 Legal Practitioners Complaints Committee v Reyburn [2005] WASAT 293 2005-07-20 found breached

    Unprofessional Conduct

    Unprofessional Conduct 1 PDF View decision
  • Nicholson, Mark Anthony
    OLSC solicitor Mark Nicholson 2005-05-27 text match

    Breach of undertaking — 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
  • Fun Huay Yew
    SG-DT lawyer Fun Huay Yew & Co 2005-04-28 found breached
    Struck off the roll with immediate effect 1 PDF View decision
  • Arthur Wayne Skagen
    LSBC lawyer 2005-04-07 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.