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discipline 3 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.

1,286 cases 62% strike-off avg suspension 13.6 mo avg fine 150,323 627 with dishonesty finding

How the codes express this duty

E&W Solicitors SRA Principles & Code CCS 6.2 strong 824 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 32 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 134 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 39 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 48 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 48 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 133 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 34 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 56 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 13 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

1,286 decisions · link basis: found breached = a tribunal finding; rule cited = the mapped provision is cited in the decision; text match = high-precision text pattern

  • Fasar Mahmood
    SDT solicitor 12687/2024 2025-06-19 found breached

    Code of Conduct for Solicitors, REL's & RFL's 2019, Dishonesty, Lack of Integrity, Misappropriation of Client Account, Solicitors Accounts Rules 2019, SRA Principles 2011

    Strike off 1 PDF View decision
  • Sarah Elizabeth Reynolds
    SDT solicitor 12509/2023 2025-06-19 found breached

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

    Fine 1 PDF View decision
  • Duren, Lillian
    OLSC solicitor Zedonga Enterprises Pty Ltd trading as LD Lawyers [2025] NSWCATOD 75 2025-06-17 found breached

    The solicitor contravened: (1) Section 148 of the Legal Profession Uniform Law (NSW) (Uniform Law): Caused, without reasonable excuse, deficiencies in accounts held by her law practice, being the trust account and statu…

    Costs Reprimand Solicitor to undertake and complete further legal education The solicitor must not apply for a practising certificate that would authorise her to be a principal of a law practice until after she has held five practising certificates for five separate practising certificate years that authorise her to engage in supervised legal practice; further, that she has, during that five year period practised as a legal practitioner. The solicitor is not authorised to receive or otherwise deal with trust money while holding a practising certificate other than one authorising her to be a principal of a Law Practice. At the time of entering into any contract of employment as a legal practitioner the solicitor is to inform the employer, in writing, of the Tribunal proceedings and the Reasons for Decision. $0.00 1 PDF View decision
  • Reid, Benjamin Paul
    OLSC solicitor Reid & Vesely 2025-06-12 found breached

    The Solicitor failed to obey the Legal Profession Uniform Law; The Solicitor’s conduct was dishonourable and contrary to the duty of legal practitioners to be honest and to have the utmost good faith in all dealings in …

    Cancellation of Practising Certificate for the year ending 30 June 2025 pursuant to section 82(1)(d) of the Legal Profession Uniform Law $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
  • Respondent AR
    SDT solicitor 12668/2024 2025-06-11 found breached

    Code of Conduct for Solicitors, REL's & RFL's 2019, Solicitors Accounts Rules 2019

    Suspend - Fixed Period 1 PDF View decision
  • Satnam Singh Talwar
    SDT solicitor 12684/2024 2025-05-30 found breached rule cited

    Breaches, Code of Conduct for Firms 2019, Lack of Integrity, SRA Principles 2019

    Fine 1 PDF View decision
  • Michael Alexander Brown
    GLC attorney 117 of 2023 2025-05-13 found breached

    Fined | Disciplinary Committee decision delivered May 13, 2025. || Guilty of Professional Misconduct | Disciplinary Committee decision delivered November 23, 2024. View PDF SANCTION DECISION OF THE DISCIPLINARY COMMITTE…

    Fined 2 PDFs View decision
  • Steven George Powell
    GLC attorney 176 of 2022 2025-05-13 found breached

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

    Reprimanded 2 PDFs View decision
  • Shaune Kerry Irving
    LSC-QLD solicitor Moloney MacCallum Abdelshahied Lawyers 2025-05-03 found breached

    Charges 1, 2 & 3 of disciplinary application 110/24 and 181/24 there is a finding of professional misconduct.

    Struck off 1 PDF View decision
  • David William McDermott
    SDT solicitor 12654/2024 2025-04-26 found breached

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

    Strike off 1 PDF View decision
  • (unnamed)
    SDT solicitor 12672/2024 2025-04-26 found breached

    Appeals

    S.44E/ S.46/Paragraph 14C Appeals 1 PDF View decision
  • Raja Shazad Khan; Ishtiaq Ahmed
    SDT solicitor 12540/2024 2025-04-14 found breached

    Breaches, Code of Conduct for Firms 2019, Dishonesty, Lack of Integrity, Solicitors Accounts Rules 2019, SRA Principles 2019

    Strike off, Suspended period of Suspension 1 PDF View decision
  • Waheed Ur Rehman Mian
    SDT solicitor 12646/2024 2025-04-14 found breached

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

    Suspend - Fixed Period 1 PDF View decision
  • Lynsay Kelly
    SSDT solicitor Lynsay Kelly, 29 St Vincent Crescent, Ayr 2025-04-08 found breached
    strike_off No Appeal 2 PDFs View decision
  • Antony Davies
    SDT solicitor 12652/2024 2025-04-01 found breached

    Breaches, Lack of Integrity

    Fine 1 PDF View decision
  • Paul Christopher Flaherty; William John Gregory Osmond
    SDT solicitor 12647/2024 2025-04-01 found breached

    Breaches, Failures, Misappropriation of Client Account, Money Laundering Regulations, Solicitors Accounts Rules 2011, SRA Principles 2011

    Fine, Suspend - Fixed Period 1 PDF View decision
  • Simpson Thacher & Bartlett LLP
    SDT solicitor 12639/2024 2025-03-21 found breached

    Breaches, Code of Conduct 2011, Code of Conduct for Firms 2019, Money Laundering Regulations, SRA Principles 2011, SRA Principles 2019

    Fine 1 PDF View decision
  • Steven John Docherty
    SSDT solicitor Steven John Docherty, Wright Johnston & Mackenzie LLP, St Vincent Plaza, 319 St Vincent Street, Glasgow 2025-03-20 found breached
    conditions No Appeal 1 PDF View decision
  • Kerr Clement
    SDT solicitor 12661/2024 2025-03-14 found breached

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

    Fine 1 PDF View decision
  • David Baynon Crosby
    SDT solicitor 12658/2024 2025-03-14 found breached

    Breaches, Client Money, Code of Conduct for Solicitors, REL's & RFL's 2019, Dishonesty, Lack of Integrity, Misappropriation of Client Account, Solicitors Accounts Rules 2019, SRA Principles 2019

    Strike off 1 PDF View decision
  • John Mark Fitzpatrick
    LPCC-SA lawyer Unit 1, 121 Walkerville Terrace, Walkerville SA 5081 2025-03-07 found breached

    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
  • Gregory George Dureault
    LSBC lawyer 2025-02-28 found breached

    Rule 3-7.1 Consent Agreement

    Rule 3-7.1 Consent Agreement 1 PDF View decision
  • Jonathan Richard Maurice Gerber
    SDT solicitor 12616/2024 2025-02-24 found breached

    Breaches, Failures, Solicitors Accounts Rules 2011, Solicitors Accounts Rules 2019, SRA Principles 2011, SRA Principles 2019

    Fine 1 PDF View decision
  • Mark Ian Williams
    SDT solicitor 12626/2024 2025-02-18 found breached

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

    Suspend - Fixed Period 1 PDF View decision
  • Bridget Catherine Miller
    SDT solicitor 12616/2024 2025-02-12 found breached

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

    Fine 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.