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discipline 4 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

  • Richard Clive Hallows
    SDT solicitor 12094/2020 2020-01-01 found breached

    Breaches, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Roger Brian Allanson
    SDT solicitor 12131/2020 2020-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Nicholas Peter William Skinnard
    SDT solicitor 12090/2020 2020-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Deian Wyn Benjamin
    SDT solicitor 12046/2020 2020-01-01 found breached

    Breaches

    Strike off 1 PDF View decision
  • Charles James Ete & Henry Onotere Mume
    SDT solicitor 12034/2020 2020-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Reprimand, Strike off 1 PDF View decision
  • Peter Hobson Brothwell
    SDT solicitor 12140/2020 2020-01-01 found breached

    Breaches, Failures

    Strike off 1 PDF View decision
  • Roger Patrick Diavewa
    SDT solicitor 12134/2020 2020-01-01 found breached
    Revocation of S.43 Order - Refused 1 PDF View decision
  • Michael Philip Pulsford
    SDT solicitor 12098/2020 2020-01-01 found breached

    Criminal Convictions

    Strike off 1 PDF View decision
  • Michael Thomas Barry & Rachel Taylor
    SDT solicitor 12051/2020 2020-01-01 found breached

    Breaches, Client Money, Solicitors' Accounts Rules

    S.43 Order (clerks), Variation of Conditions on Practising Certificate 1 PDF View decision
  • Patrick Adrien Fitzgerald
    SDT solicitor 12056/2020 2020-01-01 found breached

    Breaches

    Strike off 1 PDF View decision
  • Matthew Edward Flynn
    SDT solicitor 12062/2020 2020-01-01 found breached

    Breaches, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Lorraine Louise Ramson
    GLC attorney 19 of 2013 2019-12-20 found breached

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered December 20, 2019. || Reprimanded, Restitution ordered, Fined | Disciplinary Committee decision delivered June 23, 2020. View PDF in full scr…

    Guilty of Professional Misconduct 1 PDF View decision
  • Ivan John Poole
    LSC-QLD solicitor Ivan Poole Lawyers 2019-12-19 found breached rule cited

    Charges 1 and 4 the respondent's conduct amounts to professional misconduct. Charges 2 and 3 the respondent's conduct amounts to unsatisfactory professional conduct.

    Suspended 1 PDF View decision
  • Charles Alcides Pullar Ganga-Singh
    GLC attorney 103 of 2016 2019-12-07 found breached

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered December 07, 2019. || Fined | Disciplinary Committee decision delivered December 02, 2020. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF…

    Guilty of Professional Misconduct 3 PDFs View decision
  • Mark Lorrell
    BTAS barrister Lincoln's Inn 2019-11-13 found breached text match
    suspension Final 2 PDFs View decision
  • Hopeton Karl Clarke
    GLC attorney 137 of 2017 2019-10-26 found breached

    Struck off | Disciplinary Committee decision delivered October 26, 2019. || RESULT: Appeal dismissed | Court of Appeal decision delivered March 12, 2021. View PDF JUDGMENT OF THE DISCIPLINARY COMMITTEE SANCTION COMPLAIN…

    Struck off 1 PDF View decision
  • James (Seamus) Doody
    LSI solicitor Doody Solicitors, 21 South Mall, Cork 2019-10-18 found breached

    In the matter of James (Seamus) Doody, solicitor, practising in Doody Solicitors, 21 South Mall, Cork, and in the matter of an application by the Law Society of Ireland to the Solicitors Disciplinary Tribunal [2017/DT84…

    strike_off View decision
  • James (Seamus) Doody
    LSI solicitor Doody Solicitors, 21 South Mall, Cork 2019-10-18 found breached

    In the matter of James (Seamus) Doody, solicitor, practising in Doody Solicitors, 21 South Mall, Cork, and in the matter of an application by the Law Society of Ireland to the Solicitors Disciplinary Tribunal [6285/DT17…

    strike_off View decision
  • Maurice B O’Sullivan
    LSI solicitor Maurice O’Sullivan & Company Solicitors, 9 Colbert Street, Listowel, Co Kerry 2019-10-14 found breached

    In the matter of Maurice B O’Sullivan, a solicitor practising as Maurice O’Sullivan & Company Solicitors, at 9 Colbert Street, Listowel, Co Kerry, and in the matter of the Solicitors Acts 1954-2015 [2017/DT24, 2017/DT38…

    strike_off View decision
  • HELEN MARIE TOLSON
    LPBWA lawyer PO Box 3050 EAST PERTH WA 6892 VR 85 of 2019 2019-10-09 found breached

    Referral to Supreme Court (full bench) recommending name be removed from the roll of practitioners

    Referral to Supreme Court (full bench) recommending name be removed from the roll of practitioners 1 PDF View decision
  • Azfar Bajwa
    BTAS barrister Gray's Inn 2019-09-19 found breached
    strike_off Final 2 PDFs View decision
  • Ms Vanessa Marie FARMER
    LSNT lawyer 22 Harry Chan Ave, Darwin NT 0800 NT Jurisdiction 2019-08-30 found breached

    Findings of professional misconduct Reasons for decision Reasons for penalty

    Public reprimand in respect of each charge Fine of $15,000 Complete further legal education in the areas of Ethics and Professional Responsibility and Practice Management, course not exceeding one day or equivalent online program Transfer trust money to the complainant within 7 days 2 PDFs View decision
  • Nagle, Peter Richard
    OLSC barrister 2019-08-15 found breached

    1. Engaged in legal practice in the period since 1 July 2016, contrary to section 10 of the Legal Profession Uniform Law 2. Represented himself as entitled to engage in legal practice in the period since 1 July 2016, co…

    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
  • Richard D. Bonner
    GLC attorney 151 of 2018 2019-07-27 found breached

    Fined, Reimbursement ordered | Disciplinary Committee decision delivered July 27, 2019. | Formal Order View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO: 151/2018 IN THE MATTER OF…

    Fined, Reimbursement ordered 2 PDFs View decision
  • Raymond Clough
    GLC attorney 186 of 2010 2019-07-26 found breached

    Suspended, Fined - Disciplinary Committee decision delivered July 26, 2019. | Guilty of Professional Misconduct - Disciplinary Committee decision May 11, 2019. | Formal Order July 26, 2019 View PDF DECISION OF THE DISCI…

    Suspended, Fined - Disciplinary Committee decision delivered July 26, 2019. 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.