Skip to main content
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

  • David Wilkie-Thorburn
    SSDT solicitor David Wilkie-Thorburn, 12 Harcourt Road, Aberdeen 2022-09-16 found breached
    suspension No Appeal 2 PDFs View decision
  • Zoe Ann Lowe
    SDT solicitor 12343/2022 2022-09-14 found breached

    Breaches, Failures

    Strike off 1 PDF View decision
  • Soophia Khan
    SDT solicitor 12323/2022 2022-09-08 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Wendy Michelle Randall
    SDT solicitor 12331/2022 2022-09-07 found breached

    Breaches

    Strike off 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
  • Derek Hayward
    SDT solicitor 12304/2022 2022-07-22 found breached

    Breaches

    Strike off 1 PDF View decision
  • Sean Michael Callaghan
    SDT solicitor 12319/2022 2022-07-11 found breached

    Breaches, Client Money, Code of Conduct 2007, Code of Conduct 2011, Code of Conduct for Solicitors, REL's & RFL's 2019, Dishonesty, Lack of Integrity, Misappropriation of Client Account, Solicitors Accounts Rules 1998, …

    Strike off 1 PDF View decision
  • Ooi Oon Tat
    SG-DT lawyer Judy Cheng & Co 2022-07-01 found breached
    Suspended for a period of five (5) years 1 PDF View decision
  • Oliver W. Llewellyn
    GLC attorney 59 of 2013 2022-06-30 found breached

    Fined | Disciplinary Committee decision delivered June 30, 2022. View PDF FORMAL ORDER OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO: 59/2013 IN THE MATTER OF MICHAEL MARK ANTHONY IRVING and OL…

    Fined 1 PDF View decision
  • Ronald Grant Fulton
    SSDT solicitor Ronald Grant Fulton, 36 Newlands Road, Glasgow 2022-06-29 found breached
    fine No Appeal 1 PDF View decision
  • James Borbor Allie
    SDT solicitor 12309/2022 2022-06-29 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Patrick McGonagle
    LSI solicitor previously practising at 1 Main Street, Dundrum, Dublin 14 2022-06-20 found breached

    In the matter of Patrick McGonagle, a solicitor previously practising as McGonagle Solicitors, 1 Main Street, Dundrum, Dublin 14, and in the matter of the Solicitors Acts 1954-2015 [2020/DT03 and High Court record 2022 …

    strike_off View decision
  • Habib-Ur-Rahmaan Maroof
    SDT solicitor 12315/2022 2022-06-20 found breached

    Breaches

    Strike off 1 PDF View decision
  • Mohammud Massood Joomratty
    LSBC lawyer 2022-06-16 found breached

    Rule 3-7.1 Consent Agreement

    Rule 3-7.1 Consent Agreement 1 PDF View decision
  • Zeeshan Mian
    BTAS barrister Lincoln's Inn 2022-06-16 found breached
    strike_off appeal dismissed 2 PDFs View decision
  • Raja Shazad Khan & Colin Anthony Goldring
    SDT solicitor 12263/2021 2022-05-27 found breached
    S.43 Order (clerks) 1 PDF View decision
  • Daniel Anthony McGinn
    SSDT solicitor Daniel Anthony McGinn, 68 Sannox Drive, Glasgow 2022-05-26 found breached
    strike_off No Appeal 2 PDFs View decision
  • Hashok Parmar
    SDT solicitor 12286/2021 2022-05-13 found breached

    Criminal Convictions

    Strike off 1 PDF View decision
  • Aziz Ur-Rehman
    SDT solicitor 12288/2021 2022-05-10 found breached

    Client Money, Code of Conduct 2011, Dishonesty, Misappropriation of Client Account

    Strike off 1 PDF View decision
  • Douglas Kilpatrick
    SSDT solicitor Douglas Kilpatrick, PRP Legal Ltd, Kensington House, 227 Sauchiehall Street, Glasgow; 2022-05-04 found breached
    fine No Appeal 1 PDF View decision
  • David Ewan McNeish
    SSDT solicitor David Ewan McNeish, formerly of Optima Legal (now Alston Law) and now of DWF LLP, No. 2 Lochrin Square, 96 Fountainbridge, Edinburgh 2022-04-26 found breached
    reprimand No Appeal 2 PDFs View decision
  • Sean O’Neil Kinghorn
    GLC attorney 190 of 2020 2022-04-13 found breached

    Fined | Disciplinary Committee decision delivered April 13, 2022. || Guilty of Professional Misconduct | Disciplinary Committee decision delivered November 16, 2021 || Formal Order delivered April 19, 2022 (PDF) View PD…

    Fined 2 PDFs View decision
  • W. Anthony Pearson
    GLC attorney 93 of 2015 2022-02-28 found breached

    Guilty of Misconduct in a Professional Respect | Disciplinary Committee decision delivered February 28, 2022. || Fined | Disciplinary Committee decision delivered April 20, 2022 || Formal Order View PDF in Full Screen …

    Guilty of Misconduct in a Professional Respect 2 PDFs View decision
  • Elizabeth Catherine Nedin
    SDT solicitor 12195/2021 2022-02-23 found breached

    Client Money, Failures

    Strike off 1 PDF View decision
  • Raj Rajan Mariaddan
    SDT solicitor 12218/2021 2022-02-22 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.