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discipline 3 October 2026

The duty in context

No baseless or threatened misconduct report profession

The lawyer must not make or threaten a professional-misconduct allegation or report without a genuine, reasonably held and bona fide belief that it applies.

505 cases 43% strike-off avg suspension 15.0 mo avg fine 83,213 198 with dishonesty finding

How the codes express this duty

E&W Solicitors SRA Principles & Code no clear equivalent
E&W Barristers BSB Handbook rC67 strong 28 cases
rC67 You must never make, or threaten to make, a report under Rule rC66 without a genuine and reasonably held belief that Rule rC66 applies.
Cayman Islands Legal Services Code 2026 no clear equivalent
AU Solicitors Solicitors' Conduct Rules Rule 32.1 strong 198 cases
A solicitor must not make an allegation against another Australian legal practitioner of unsatisfactory professional conduct or professional misconduct unless the allegation is made bona fide and the solicitor believes on reasonable grounds that available material by which the allegation could be supported provides a proper basis for it.
AU Barristers Uniform Barristers Rules no clear equivalent
IE Solicitors Law Society Guide no clear equivalent
IE Barristers Bar Code of Conduct no clear equivalent
JM Attorneys Canons of Professional Ethics no clear equivalent
JE Lawyers Law Society of Jersey Code no clear equivalent
ON Lawyers LSO Rules of Prof. Conduct r 3.2-5(b); r 7.1-3 commentary [1] partial
3.2-5 A lawyer shall not, in an attempt to gain a benefit for a client, threaten, or advise a client to threaten, without reasonable and lawful justification ... (b) to make a complaint to a regulatory authority. [7.1-3 commentary [1]: In all cases, the report must be made without malice or ulterior motive. 3.2-5 commentary [1]: It is an abuse of the process of a court or, ordinarily, a regulatory authority to threaten to make or advance a charge or complaint in order to secure the satisfaction of a private grievance.]
BC Lawyers BC Code r 7.1-3, commentary [2] partial 37 cases
Nothing in this paragraph is meant to interfere with the lawyer-client relationship. In all cases, the report must be made without malice or ulterior motive.
NZ Lawyers Conduct & Client Care Rules r 2.10 strong
A lawyer must not use, or threaten to use, the complaints or disciplinary process for an improper purpose.
SCO Solicitors LSS Standards of Conduct no clear equivalent
SG Lawyers Professional Conduct Rules 2015 r 29 (Allegations against another legal practitioner) partial 6 cases
29 Allegations against another legal practitioner
HK Solicitors Solicitors' Guide no clear equivalent
HK Barristers Bar Code of Conduct para 10.50 partial
A practising barrister shall not make any allegation of misconduct or dishonesty against another barrister unless such allegation is supported by reasonably credible evidence.

Cases dealing with this duty

Clear

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

  • Dexter Charles Anthony Wadsworth
    GLC attorney 139 of 2008 2021-11-24 found breached

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered November 24, 2021. || Struck off | Disciplinary Committee decision delivered January 18, 2022. View PDF DECISION OF THE DISCIPLINARY COMMITTE…

    Guilty of Professional Misconduct 1 PDF View decision
  • Hughes, Owen Maldwyn
    OLSC solicitor Beesley & Hughes 2021-11-24 found breached

    Allegation 1 - The Lawyer engaged in sexual harassment and / or workplace bullying in breach of Rule 42 of the Legal Profession Uniform Law Australian Solicitors’ Conduct Rules 2015 (“the Solicitors’ Rules”) Further, or…

    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
  • Martin Doyle
    LSC-QLD solicitor 2021-11-09 found breached

    The respondent engaged in professional misconduct.

    Struck off 1 PDF View decision
  • Angela Walker
    LSC-QLD barrister 2021-11-05 found breached

    The respondents conduct amounts to professional misconduct

    Struck off 1 PDF View decision
  • Tracey Anne SMITH
    LSC-QLD solicitor Smith Legal Solutions 2021-10-25 found breached

    In respect of charges 1-5 & 7-12 the Respondent is guilty of professional misconduct.

    Struck off 1 PDF View decision
  • Lorraine Louise Ramson
    GLC attorney 263 of 2017 2021-10-09 found breached

    Struck off, Payment Ordered | Disciplinary Committee decision delivered October 09, 2021. View PDF FORMAL ORDER OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO: 263/2017 IN THE MATTER OF CLAUDINE…

    Struck off, Payment Ordered 1 PDF View decision
  • Edward Pene
    LSC-QLD solicitor 2021-09-23 found breached

    In respect of Charge 4, there is a finding that the Respondent engaged in professional misconduct. In respect of each of Charges 2, 3 and 5, there is a finding that the Respondent engaged in unsatisfactory professional …

    Suspended 1 PDF View decision
  • George Roland Holland
    LSBC lawyer 2021-09-15 found breached

    Rule 3-7.1 Consent Agreement | Summary

    Rule 3-7.1 Consent Agreement | Summary 1 PDF View decision
  • KELVIN KA CHUEN TANG
    LPBWA lawyer Suite 2 191 James Street NORTHBRIDGE WA, 6003 Legal Profession Complaints Committee v Tang [2021] WASAT 2021-09-03 found breached

    Professional Misconduct

    Professional Misconduct 1 PDF View decision
  • Michelle Cherie Harrington
    LSC-QLD solicitor Harrington Legal 2021-08-23 found breached

    In respect of each of Charges 1, 2, 3, 6 and 7, there is a finding that the Respondent engaged in professional misconduct. In respect of each of Charges 4 and 5, there is a finding that the Respondent engaged in unsatis…

    Suspended 1 PDF View decision
  • Craig Leonard Stevenson
    LSC-QLD solicitor A Ace Solicitors 2021-08-12 found breached

    In respect of each of Charges 2, 3, 4, 5 and 6, there is a finding that the Respondent engaged in professional misconduct

    Other 1 PDF View decision
  • Leonardo Fernando Christie
    GLC attorney 199 of 2020 2021-08-10 found breached

    Struck off | Disciplinary Committee decision delivered July 24th, 2021. View PDF FORMAL ORDER OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO: 199/2020 IN THE MATTER OF TINA GOLLAB and LEONARDO F…

    Struck off 1 PDF View decision
  • Kernaghan, Aaron Noel
    OLSC solicitor Kernaghan & Associates Pty Ltd [2021] NSWCATOD 111 2021-08-06 found breached

    Professional Misconduct Breached an undertaking to the Office of the Legal Services Commissioner Breach section 137 of the Legal Profession Uniform Law (NSW) - Certain trust money to be deposited in general trust accoun…

    To be determined by the Tribunal $0.00 1 PDF View decision
  • Clifton, David Vincent
    OLSC solicitor Clifton Legal [2021] NSWCATOD 101 2021-07-27 found breached

    Breach of section 138(1)(b) of the Legal Profession Uniform Law - Holding, disbursing and accounting for trust money in general trust account Breach of section 148 of the Legal Profession Uniform Law - Deficiency in tru…

    Costs Order recommending removal of lawyer's name from the Roll of Australian Lawyers On 10 December 2021, NSW Supreme Court Court of Appeal ordered: 1. The name of the respondent David Vincent Clifton be removed from the roll kept by the Supreme Court of New South Wales. (2) The respondent pay the applicant’s costs. $0.00 Disciplinary Action 2 PDFs View decision
  • Jacqueline Marie Minto
    GLC attorney 138 of 2020 2021-06-19 found breached

    Fined | Disciplinary Committee decision delivered June 19, 2021. || RESULT: Guilty of Professional Misconduct, Fined | Disciplinary Committee decision delivered June 19, 2021. View PDF FORMAL ORDER OF THE DISCIPLINARY C…

    Fined 1 PDF View decision
  • Jacqueline Marie Minto
    GLC attorney 138 of 2020 2021-06-19 found breached

    Guilty of Professional Misconduct, Fined | Disciplinary Committee decision delivered June 19, 2021. || RESULT: Fined | Disciplinary Committee decision delivered June 19, 2021. View PDF DECISION OF THE DISCIPLINARY COMMI…

    Guilty of Professional Misconduct, Fined 1 PDF View decision
  • ARTHUR METAXAS
    LPBWA lawyer Level 4 37 St Georges Tce PERTH WA 6000 Legal Practitioners Complaints Committee v Metaxas [2021] WASAT 82 2021-06-14 found breached

    Unsatisfactory Professional Conduct

    Unsatisfactory Professional Conduct 2 PDFs View decision
  • DAVID CHARLES MIZEN
    LPBWA lawyer Shop 5 6 Canning Road KALAMUNDA WA 6076 Legal Practitioners Complaints Committee v Mizen [2021] WASAT 80 2021-06-02 found breached

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

    Professional Misconduct. Referral to Supreme Court (full bench) recommending name be removed from the roll of practitioners 1 PDF View decision
  • Jennifer Messado
    GLC attorney 145 of 2015 2021-05-29 found breached

    Struck off, Restitution Ordered | Disciplinary Committee decision delivered May 29, 2021. View PDF FORMAL ORDER OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL MADE ON COMPLAINT NO: 145/2015 IN THE MATTER OF …

    Struck off, Restitution Ordered 1 PDF View decision
  • Buckley, Nathan Andrew
    OLSC solicitor G & B Lawyers 2021-05-20 text match

    Statements encouraging breaches of law Making unfounded allegations against other practitioners Failure to provide information to the regulatory authority Offensive, threatening and/or abusive language and threatening t…

    Fine Reprimand Solicitor to undertake and complete further legal education $2,500.00 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
  • Leslie, James Edward
    OLSC solicitor Leslie Hargrave Pty Ltd [2021] NSWCA 59 2021-04-21 found breached

    Ground 1: Caused a deficiency in the trust account Ground 2: Misappropriated trust funds Ground 3: Manipulated trust accounting records to conceal misappropriation of trust money Ground 4: Breaches of trust account obli…

    Costs Removal of lawyer's name from the Roll of Local Lawyers $0.00 1 PDF View decision
  • Femida Jamali
    SDT solicitor 12205/2021 2021-01-01 found breached

    Breaches, Failures

    Strike off 1 PDF View decision
  • Sam Themis
    SDT solicitor 12212/2021 2021-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Briana Christine Ioannides
    LSC-QLD solicitor 2020-12-17 found breached

    Guilty of professional misconduct

    Struck off 1 PDF View decision
  • Aiden Blair Anderson
    LSC-QLD solicitor Blair Anderson 2020-12-03 found breached

    On Charge 1 the respondent engaged in unsatisfactory professional conduct. On Charge 2 the respondent engaged in professional misconduct.

    Other 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.