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discipline 1 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.

1,282 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

  • Andrew Thomas Benson
    SDT solicitor 11404/2015 2015-01-01 found breached

    Breaches, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Philip Crowe
    SDT solicitor 11335/2015 2015-01-01 found breached

    Client Money, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Deidre Dain Newell-Austin & Najma Nahid Assroundi & Rashad Ahsan
    SDT solicitor 11359/2015 2015-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off, Strike Off Register of Foreign Lawyers 1 PDF View decision
  • Simon Michael Armitage
    SDT solicitor 11347/2015 2015-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Niall O'Kelly
    LSI solicitor Niall O’Kelly Solicitors, 52 Fortfield Park, Terenure, Dublin 6W 2014-10-20 found breached

    In the matter of Niall O’Kelly, a solicitor previously practising as Niall O’Kelly Solicitors, 52 Fortfield Park, Terenure, Dublin 6W, and in the matter of the Solicitors Acts 1954-2011 [5202/DT156/12, 5202/DT11/13 and …

    strike_off View decision
  • GEOFFREY PAUL DUTTON
    LPBWA lawyer Level 1 195 Adelaide Terrace PERTH WA 6000 Legal Profession Complaints Committee v Dutton [2014] WASAT 2014-09-23 found breached

    Professional Misconduct

    Professional Misconduct 1 PDF View decision
  • Angela Farrell
    LSI solicitor Farrell Solicitors, 28 North Great George’s Street, Dublin 1 2014-06-24 found breached

    In the matter of Angela Farrell, a solicitor formerly practising as Farrell Solicitors, 28 North Great George’s Street, Dublin 1, and in the matter of the Solicitors Acts 1954-2011 [6102/DT112/13 and 2014 no 57SA] Law S…

    strike_off View decision
  • David Walsh
    LSI solicitor David Walsh & Co, Solicitors, 12 Mount Street, Mullingar, Co Westmeath 2014-05-27 found breached

    In the matter of David Walsh, solicitor, formerly practising as David Walsh & Co, Solicitors, at 12 Mount Street, Mullingar, Co Westmeath, and in the matter of the Solicitors Acts 1954-2011 [4550/DT04/12and 2014 no 38 S…

    strike_off View decision
  • David Walsh
    LSI solicitor David Walsh & Co, Solicitors, 12 Mount Street, Mullingar, Co Westmeath 2014-05-27 found breached

    In the matter of David Walsh, solicitor, formerly practising as David Walsh & Co, Solicitors, at 12 Mount Street, Mullingar, Co Westmeath, and in the matter of the Solicitors Acts 1954-2011 [4550/DT20/12 and 2014 no 39 …

    strike_off View decision
  • Downie, Daniel Mcgregor
    OLSC solicitor (Formerly) Downie & Co [2014] NSWCATOD 60 2014-05-23 found breached

    1. Breaches of Section 255 LPA 2004 - disbursing trust money without authority 2. Breaches of Section 264 LPA 2004 - failing to keep trust records in a way that discloses true position 3. Misappropriation 4. Causing a d…

    Costs Removal of practitioner's name from the Roll of Local Lawyers $0.00 Proceedings Instituted View decision
  • CHARLENE SHEILA AMSDEN
    LPBWA lawyer PO Box 3440 NEDLANDS WA 6005 Legal Profession Complaints Committee v Amsden [2014] WASAT 57 and [2014] WASAT 57 (S) 2014-05-22 found breached

    Professional Misconduct

    Professional Misconduct 2 PDFs View decision
  • Christopher William Hales
    SSDT solicitor Christopher William Hales, 74/1 Spottiswoode Street, Edinburgh 2014-05-13 found breached
    strike_off No Appeal 1 PDF View decision
  • Aiden Barry
    LSI solicitor Aiden Barry Solicitor, Roche House, 8 Bank Place, Limerick, Co Limerick 2014-04-28 found breached

    I n the matter of Aiden Barry, solicitor, formerly practising as Aiden Barry Solicitor, Roche House, 8 Bank Place, Limerick, Co Limerick, and in the matter of the Solicitors Acts 1954-2011 [7243/DT58/13 and High Court r…

    strike_off View decision
  • Richard Thomas Thorburn
    SSDT solicitor Richard Thomas Thorburn, 31 Braemar Street, Glasgow 2014-04-14 found breached
    restoration_refused 1 PDF View decision
  • Leighton O. Miller
    GLC attorney 5 of 2010 2014-03-22 found breached

    Suspended, Restitution Ordered | Disciplinary Committee decision delivered March 22, 2014. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO: 5/2010 BETWEEN RICARDO BOND COMPLAINA…

    Suspended, Restitution Ordered 1 PDF View decision
  • Denise McNulty
    LSI solicitor Denise McNulty & Co, Solicitors, Zion Court, Zion Church Grounds, Rathgar, Dublin 6 2014-03-10 found breached

    In the matter of Denise McNulty, solicitor, practising as Denise McNulty & Co, Solicitors, Zion Court, Zion Church Grounds, Rathgar, Dublin 6, and in the matter of the Solicitors Acts 1954-2011 [4457/DT113/13 and High C…

    conditions View decision
  • Elsie A. Taylor
    GLC attorney 175 of 1996 2014-02-10 found breached

    Repayment Ordered | Disciplinary Committee decision & Review delivered November 28, 2003. | Decision affirmed on appeal View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL Complaint# 175 of 1996…

    Repayment Ordered 1 PDF View decision
  • Christopher James Anderson
    SDT solicitor 11269/2014 2014-01-01 found breached

    Breaches, Failures

    Strike off 1 PDF View decision
  • Ogunniyi & Adhikari
    SDT solicitor 11265/2014 2014-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Strike off, Suspend - Fixed Period 1 PDF View decision
  • Stephen Jackson
    SDT solicitor 11296/2014 2014-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Kanwar Bhan
    SDT solicitor 11320/2014 2014-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Reprimand, Strike off 1 PDF View decision
  • Hector Diaz Suner
    SDT solicitor 11230/2014 2014-01-01 found breached

    Breaches, Client Money, Failures, Others

    Strike Off Register of Foreign Lawyers 1 PDF View decision
  • Robert Andrew Schofield
    SDT solicitor 11322/2014 2014-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Gail Evans
    SDT solicitor 11285/2014 2014-01-01 found breached

    Criminal Convictions

    Strike off 1 PDF View decision
  • Pascale Edith Marie-Anne Wood-Atkins
    SDT solicitor 11270/2014 2014-01-01 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.