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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

  • Gboyega Ajibola Okunniga
    SDT solicitor 12754/2025 2026-03-19 found breached

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

    Strike off 1 PDF View decision
  • Darren Hanison
    SDT solicitor 12764/2025 2026-03-19 found breached

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

    Strike off 1 PDF View decision
  • Respondent AO
    SDT solicitor 12650/2024 2026-03-16 found breached

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

    Strike off 1 PDF View decision
  • Jude Sebastian Fletcher
    SDT solicitor 12765/2025 2026-03-13 found breached

    Client Money, Code of Conduct for Solicitors, REL's & RFL's 2019, Solicitors Accounts Rules 2019, SRA Principles 2019

    Strike off 1 PDF View decision
  • Shivani Jegarajah
    BTAS barrister Middle Temple 2026-03-09 found breached
    fine open to appeal 2 PDFs View decision
  • Phillip David Gallasch
    LPCC-SA lawyer 100 Philip Highway, Elizabeth SA 5112 2026-02-25 found breached

    The Practitioner was the victim of a third-party cyber fraud which resulted in the loss of $149,588.28 of his client’s money. The Practitioner failed to verify the banking details received by email with his client by te…

    Reprimand View decision
  • Mark Christopher Sander
    LPCC-SA lawyer 9 Hackney Road, Hackney SA 5069 2026-02-18 found breached

    1. On 1 May 2014, the Practitioner opened a trust account. The Legal Practitioners Act 1981 (Act) imposes obligations on Practitioners who open trust accounts including an obligation to provide written notice of the ope…

    Multiple Disciplinary Action Conditions on Practising Certificate Fine Reprimand Submit to medical treatment / counselling View decision
  • Timothy Eagle
    SDT solicitor 12731/2025 2026-02-17 found breached

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

    Suspend - Fixed Period 1 PDF View decision
  • Alexander David Edmund Hayes Gallagher
    SDT solicitor 12772/2025 2026-02-11 found breached

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

    Strike off 1 PDF View decision
  • Chinyere Inyama
    SDT solicitor 12814/2025 2026-02-11 found breached

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

    Strike off 1 PDF View decision
  • Paul Lloyd Jones
    SDT solicitor 12520/2023 2026-01-29 found breached

    SRA Principles 2011

    Strike off 1 PDF View decision
  • Joe Morgan
    SDT solicitor 12587/2024 2026-01-19 found breached

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

    Strike off 1 PDF View decision
  • Andrew Brian Alexander Cooper
    SDT solicitor 12737/2025 2026-01-19 found breached

    Code of Conduct for Solicitors, REL's & RFL's 2019, Dishonesty, Solicitors Accounts Rules 2011, Solicitors Accounts Rules 2019, SRA Principles 2011, SRA Principles 2019

    Strike off 1 PDF View decision
  • (unnamed)
    SDT solicitor 12851/2025 2026-01-16 found breached

    Client Money, Failures

    Variation of Conditions on Practising Certificate 1 PDF View decision
  • Md Zahidul Islam; Zarina Shaheen Bostan; Nageena Choudhry; Mohammed Saleem
    SDT solicitor 12651/2024 2026-01-08 found breached

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

    Fine, Not Proved/Dismissed 1 PDF View decision
  • Jack Alexander Williams
    SDT solicitor 12742/2025 2025-12-24 found breached

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

    Suspend - Fixed Period 1 PDF View decision
  • Nachiappan, Sorna
    OLSC solicitor 2025-12-18 found breached

    It appears the Lawyer has: Inserted signatures into four (4) costs agreements without authorisation Provided those costs agreements to the Office of the NSW Legal Services Commissioner (NSW Commissioner) in an attempt t…

    Cancellation of Practising Certificate for the practising year ending 30 June 2026 on the ground that the Lawyer is unable to fulfil the inherent requirements of an Australian legal practitioner: s 82(1)(d) of the Legal Profession Uniform Law (NSW) (Uniform Law); and Restricted the Lawyer from applying for the grant of a practising certificate for a period of two (2) years: s 94 of the 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
  • Eric Kawoya Kabuye
    SDT solicitor 12703/2024 2025-12-12 found breached

    Client Money, Code of Conduct for Firms 2019, Code of Conduct for Solicitors, REL's & RFL's 2019, Solicitors Accounts Rules 2019, SRA Principles 2019

    Suspended period of Suspension 1 PDF View decision
  • Siobhan Sullivan
    SSDT solicitor Siobhan Sullivan, c/o Bridge Legal Limited, Carlton Buildings, 63 Carlton Place, Glasgow 2025-12-04 found breached
    strike_off No Appeal 1 PDF View decision
  • Paul Simon Green
    SDT solicitor 12774/2025 2025-12-02 found breached

    Breaches, Code of Conduct 2007, Dishonesty, SRA Principles 2011

    Strike off 1 PDF View decision
  • Yeo Yao Hui, Charles (Yang Yaohui)
    SG-DT lawyer M/S L F Violet Netto; Whitefield Law Corporation; S K Kumar Law Practice LLP 2025-11-28 found breached
    Struck off the roll with immediate effect 1 PDF View decision
  • Ravi Sidhu
    BTAS barrister Inner Temple 2025-11-24 found breached
    strike_off Final 2 PDFs View decision
  • Antoneita Alicia Hall
    GLC attorney 177 of 2024 2025-11-22 found breached

    Guilty of Misconduct in a Professional Respect | Disciplinary Committee decision delivered November 22, 2025. || Suspended | Disciplinary Committee decision delivered February 28, 2026. View PDF DECISION OF THE DISCIPLI…

    Guilty of Misconduct in a Professional Respect 1 PDF View decision
  • McCarron, Christopher Francis
    OLSC solicitor HB Legal Pty Ltd [2025] NSWCATOD 154 2025-11-14 found breached

    The solicitor acted in a conflict of interest in connection with the sale of properties in circumstances where he and his wife, were: (a) the creditors and second mortgagees at the time of the sale of one property; and/…

    Costs Fine Reprimand The Respondent’s application for an order for confidentiality pursuant to s 64 of the Civil and Administrative Tribunal Act 2013 (NSW) (“the NCAT Act”) is dismissed. $3,000.00 1 PDF View decision
  • Zhou, Ren
    OLSC solicitor Ren Zhou Group Pty Ltd trading as Ren Zhou Lawyers 2025-11-06 found breached

    The solicitor, as principal of a law practice: Caused a deficiency in the trust account by withdrawing trust money for payment of legal costs without complying with legislative requirements Mixed trust money with other …

    Fine Reprimand Satisfactory completion of a Practice Management Course $2,000.00 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

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.