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discipline 30 September 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

  • John Charles Wright
    SDT solicitor 12402/2022 2023-02-17 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Fine 1 PDF View decision
  • Michael William Pilkington
    SDT solicitor 12377/2022 2023-01-30 found breached

    Breaches, Failures

    Strike off 1 PDF View decision
  • Gordon William Tulloch Murphy
    SSDT solicitor Gordon William Tulloch Murphy, 12 Abercromby Place, Stirling 2023-01-19 found breached
    fine No Appeal 1 PDF View decision
  • Umar Rehman
    SDT solicitor 12387/2022 2023-01-10 found breached

    Breaches, Failures

    Strike off 1 PDF View decision
  • Calvin Benjamin Rose
    GLC attorney 226 of 2018 2023-01-04 found breached

    Suspended, Fined | Disciplinary Committee decision delivered January 04, 2023. || Guilty of Professional Misconduct | Disciplinary Committee decision delivered July 30, 2022. View PDF of Decision in Full Screen View For…

    Suspended, Fined 2 PDFs View decision
  • Analiza Abella Kjaer
    SDT solicitor 12367/2022 2022-12-22 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Richard Yan-Yun Liu
    LSBC lawyer 2022-12-14 found breached

    Rule 3-7.1 Consent Agreement

    Rule 3-7.1 Consent Agreement 1 PDF View decision
  • Green, Barbara Ann
    OLSC solicitor Hermann & Green [2022] NSWCA 257 2022-12-14 found breached

    Serious criminal conduct - dishonestly obtaining financial advantage by deception contrary to s 192E(1)(b) of the Crimes Act 1900 (NSW) Taking deliberate advantage on numerous occasions of opportunities arising out of h…

    Costs Removal of lawyer’s name from the Roll of Australian lawyers $0.00 Proceedings Instituted 1 PDF View decision
  • Stephen David Jones
    SDT solicitor 12312/2022 2022-12-13 found breached

    Breaches, Failures

    Strike off 1 PDF View decision
  • Tom Kwing Ming Li
    SDT solicitor 11796/2018 2022-12-09 found breached

    Breaches, Failures

    Strike off 1 PDF View decision
  • Dustin Gerald Ellis
    LSBC lawyer 2022-12-09 found breached

    Rule 3-7.1 Consent Agreement

    Rule 3-7.1 Consent Agreement 1 PDF View decision
  • James Thomas Haigh
    SDT solicitor 12357/2022 2022-12-09 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Michael Gerard Kilkerr
    SSDT solicitor Michael Kilkerr, of Michael G Kilkerr, 1 Bridge Street, Stranraer 2022-12-06 found breached
    fine No Appeal 2 PDFs View decision
  • Simon Pak Hei Lin
    LSBC lawyer 2022-11-24 found breached

    Rule 3-7.1 Consent Agreement

    Rule 3-7.1 Consent Agreement 1 PDF View decision
  • Gail Enright
    LSI solicitor 2022-11-21 found breached

    In the matter of Gail Enright, a solicitor formerly practising in Michael Enright & Co, Solicitors, 28 South Mall, Cork, and in the matter of the Solicitors Acts 1954-2015 [2018/DT85 and High Court record 2022/198SA] La…

    strike_off View decision
  • Md Mohiuddin Hossain
    SDT solicitor 12348/2022 2022-11-21 found breached

    Breaches

    Strike off 1 PDF View decision
  • Saaima Khalid
    SSDT solicitor Saaima Khalid, JKR Law Limited, 103 West Regent Street, Glasgow 2022-11-15 found breached
    dismissed No Appeal 5 PDFs View decision
  • Richard Charles Boyd
    SDT solicitor 12338/2022 2022-11-07 found breached

    Breaches, Failures

    Strike off 1 PDF View decision
  • Paul Otto De Lange
    LSBC lawyer 2022-11-07 found breached

    Rule 4-29 Admission of Misconduct and Undertaking to the Discipline Committee

    Rule 4-29 Admission of Misconduct and Undertaking to the Discipline Committee 1 PDF View decision
  • Brian Sarney
    SDT solicitor 12339/2022 2022-10-06 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Ziesolleck, Stefan Arthur
    OLSC solicitor Norton Rose Fulbright Australia 2022-10-06 found breached

    1. The Respondent Lawyer failed to inform the Complainant of a (potential) conflict of interest arising in respect of his involvement and handling of the matter. 2. The Respondent Lawyer sent correspondence which exceed…

    Reprimand Solicitor to undertake and complete further legal education Provide a written apology to the complainant $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
  • Jayesh Sasdev
    SDT solicitor 12270/2021 2022-10-05 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Gabriel Ezeh Gabman
    SDT solicitor 12333/2022 2022-09-16 found breached
    Restoration to the Roll - Refused 1 PDF View decision
  • Alina Victorovna Nikolaeva
    LSBC lawyer 2022-08-31 found breached

    Rule 3-7.1 Consent Agreement

    Rule 3-7.1 Consent Agreement 1 PDF View decision
  • Chia Chwee Imm Helen Mrs Helen Thomas
    SG-DT lawyer 2022-08-02 found breached
    Struck off the roll with effect from 15 August 2022 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.