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discipline 30 September 2026

The duty in context

Honour professional undertakings profession

The lawyer is personally bound to honour and perform within the agreed or a reasonable time any undertaking given, and must not give an undertaking they cannot fulfil or use one as an improper inducement.

450 cases 55% strike-off avg suspension 13.1 mo avg fine 77,603 105 with dishonesty finding

How the codes express this duty

E&W Solicitors SRA Principles & Code CCS 1.3 strong 224 cases
1.3 You perform all undertakings given by you, and do so within an agreed timescale or if no timescale has been agreed then within a reasonable amount of time.
E&W Barristers BSB Handbook rC11; gC33 partial 1 case
rC11 You must within an agreed timescale or within a reasonable period of time comply with any undertaking you give in the course of conducting litigation.
Cayman Islands Legal Services Code 2026 R.11.4 strong
An attorney-at-law who has given a personal undertaking to another attorney-at-law or a recognised law entity in the course of practice is personally bound by that undertaking, shall honour that undertaking and shall ensure that it is performed in a timely and effective manner, unless the attorney-at-law is clearly and unequivocally released by the recipient or the Court.
AU Solicitors Solicitors' Conduct Rules Rule 6.1 strong 92 cases
A solicitor who has given an undertaking in the course of legal practice must honour that undertaking and ensure the timely and effective performance of the undertaking, unless released by the recipient or by a court of competent jurisdiction.
AU Barristers Uniform Barristers Rules no clear equivalent
IE Solicitors Law Society Guide Ch6 — Undertakings: General; General guidance on undertakings strong 84 cases
A solicitor is required to honour the terms of an undertaking as a matter of professional conduct. A breach of an undertaking is a matter of professional misconduct... An undertaking should not be given by a solicitor as an inducement to a client to secure that client's business... A solicitor who gives an undertaking that is expressed to be dependent upon the happening of a future event should notify the recipient promptly if it becomes clear that the event will not occur.
IE Barristers Bar Code of Conduct no clear equivalent
JM Attorneys Canons of Professional Ethics Canon VI(c); Canon VI(d); Canon VI(e) strong 25 cases
(c) An Attorney shall not commit a breach of an undertaking given by him to a Judge, a Court or other tribunal or an official thereof ... (d) An Attorney shall not give a professional undertaking which he cannot fulfil and shall fulfil every such undertaking which he gives.
JE Lawyers Law Society of Jersey Code R.10.4 strong
A member who has given, or whose employee has given, an undertaking to another member or the firm of another member in the course of practice is personally bound by that undertaking and must honour that undertaking and ensure that it is performed in a timely and effective manner.
ON Lawyers LSO Rules of Prof. Conduct r 7.2-11; r 5.1-6 strong
7.2-11 A lawyer shall not give an undertaking that cannot be fulfilled and shall fulfill every undertaking given and honour every trust condition once accepted. [5.1-6: A lawyer must strictly and scrupulously fulfill any undertakings given by him or her and honour any trust conditions accepted in the course of litigation.]
BC Lawyers BC Code r 7.2-11 strong 7 cases
A lawyer must: (a) not give an undertaking that cannot be fulfilled; (b) fulfill every undertaking given; and (c) honour every trust condition once accepted.
NZ Lawyers Conduct & Client Care Rules r 10.5 strong
A lawyer must honour all undertakings, whether written or oral, that the lawyer gives to any person in the course of practice.
SCO Solicitors LSS Standards of Conduct B1.14 partial 8 cases
You must act with other regulated persons in a manner consistent with persons having mutual trust and confidence in each other.
SG Lawyers Professional Conduct Rules 2015 r 7 (Responsibilities of legal practitioners to each other) partial 6 cases
7 Responsibilities of legal practitioners to each other
HK Solicitors Solicitors' Guide Principle 14.02 / Principle 14.01 strong
A solicitor must honour the terms of a professional undertaking. ... An undertaking shall only be given by a solicitor and is binding upon him personally, and if given in the course of practice, also binds his firm. ... an undertaking should never be given unless the solicitor giving it is certain that he personally can comply with it.
HK Barristers Bar Code of Conduct para 10.4 strong
A practising barrister, while engaging in practice, must not give any undertaking that cannot be fulfilled and must fulfil every undertaking that has been given by him.

Cases dealing with this duty

Clear

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

  • Ambrose Steen
    LSI solicitor Tullamore, Co Offaly 2014-11-03 found breached text match

    In the matter of Ambrose Steen, solicitor, and in the matter of the Solicitors Acts 1954-2011 [2851/DT55/13, 2851/DT149/13, 2851/DT164/13, 2851/DT171/13 and 2851/DT07/14 and High Court record 2014 no 129 SA] Law Society…

    strike_off View decision
  • Niall O'Kelly
    LSI solicitor Niall O’Kelly Solicitors, 52 Fortfield Park, Terenure, Dublin 6W 2014-10-20 found breached

    In the matter of Niall O’Kelly, a solicitor previously practising as Niall O’Kelly Solicitors, 52 Fortfield Park, Terenure, Dublin 6W, and in the matter of the Solicitors Acts 1954-2011 [5202/DT156/12, 5202/DT11/13 and …

    strike_off View decision
  • Arraj, Jason
    OLSC solicitor Jason Arraj Solicitor [2014] NSWCATOD 117 2014-10-16 text match

    1. Failure to comply with undertaking to fulfil Mandatory Continuing Legal Education requirements 2. Contravened a condition of his practising certificate — Professional Misconduct

    Costs Fine Reprimand $2,000.00 Proceedings Instituted View decision
  • Fergus Appelbe
    LSI solicitor Appelbe & Co, Solicitors, 34 South Main Street, Bandon, Co Cork 2014-10-13 found breached

    In the matter of Fergus Appelbe, solicitor, formerly practising in the firm of PJ O’Driscoll, 41 South Main Street, Bandon, Co Cork, and now practising as Appelbe & Co, Solicitors, 34 South Main Street, Bandon, Co Cork,…

    conditions View decision
  • Papantoniou, Stella
    OLSC solicitor Papantoniou Blake Lawyers [2014] NSWCATOD 98 2014-09-10 text match

    1. Unexplained failure to comply with her undertaking 2. Failure to comply with Section 660 Notice requiring provision of information and documents — Professional Misconduct

    Costs Removal of practitioner's name from the Roll of Local Lawyers 10/09/2014 (Finding) 28/11/2014 (Disciplinary Action) $0.00 Proceedings Instituted View decision
  • John JA Rynne
    LSI solicitor Rynne Hanrahan & Associates, Abbington House, 4 Limerick Road, Ennis, Co Clare, and Hanrahan Rynne Solicitors, 3B Riverside Business Park, Ennis, Co Clare 2014-06-30 found breached

    In the matter of John JA Rynne, solicitor, formerly practising as Rynne Hanrahan & Associates, Abbington House, 4 Limerick Road, Ennis, Co Clare, and in the firm of Hanrahan Rynne Solicitors, 3B Riverside Business Park,…

    strike_off View decision
  • John JA Rynne
    LSI solicitor Rynne Hanrahan & Associates, Abbington House, 4 Limerick Road, Ennis, Co Clare, and Hanrahan Rynne Solicitors, 3B Riverside Business Park, Ennis, Co Clare 2014-06-30 found breached

    In the matter of John JA Rynne, solicitor, formerly practising as Rynne Hanrahan & Associates, Abbington House, 4 Limerick Road, Ennis, Co Clare, and in the firm of Hanrahan Rynne Solicitors, 3B Riverside Business Park,…

    strike_off View decision
  • David Walsh
    LSI solicitor David Walsh & Co, Solicitors, 12 Mount Street, Mullingar, Co Westmeath 2014-05-27 found breached text match

    In the matter of David Walsh, solicitor, formerly practising as David Walsh & Co, Solicitors, at 12 Mount Street, Mullingar, Co Westmeath, and in the matter of the Solicitors Acts 1954-2011 [4550/DT68/11 and 2014 no 36 …

    strike_off View decision
  • David Walsh
    LSI solicitor David Walsh & Co, Solicitors, 12 Mount Street, Mullingar, Co Westmeath 2014-05-27 found breached text match

    In the matter of David Walsh, solicitor, formerly practising as David Walsh & Co, Solicitors, at 12 Mount Street, Mullingar, Co Westmeath, and in the matter of the Solicitors Acts 1954-2011 [4550/DT124/12 and 2014 no 70…

    strike_off View decision
  • Cindy McCarthy Yates
    LSI solicitor McCarthy Solicitors, 5 The Old Market, Market Street, Bandon, Co Cork 2014-04-18 found breached text match

    In the matter of Cindy McCarthy Yates, a solicitor practising under the style and title of McCarthy Solicitors at 5 The Old Market, Market Street, Bandon, Co Cork, and in the matter of the Solicitors Acts 1954-2011 [123…

    strike_off View decision
  • Leighton O. Miller
    GLC attorney 5 of 2010 2014-03-22 rule cited

    Suspended, Restitution Ordered | Disciplinary Committee decision delivered March 22, 2014. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO: 5/2010 BETWEEN RICARDO BOND COMPLAINA…

    Suspended, Restitution Ordered 1 PDF View decision
  • James O'Mahony
    LSI solicitor James O’Mahony, Solicitors, 16 Stoneybatter, Dublin 7 2014-01-31 found breached text match

    In the matter of James O’Mahony, a solicitor previously practising as James O’Mahony, Solicitors, at 16 Stoneybatter, Dublin 7, and in the matter of the Solicitors Acts 1954-2011 [4831/DT109/12; 4831/DT110/12; 4831/DT11…

    strike_off View decision
  • Ruairi O’Ceallaigh
    LSI solicitor Sean O’Ceallaigh & Co., The Old Bank, Phibsboro, Dublin 7 2014-01-13 found breached

    In the matter of Ruairi O’Ceallaigh, a solicitor formerly practising in the firm of Sean O’Ceallaigh, Solicitors, and in the matter of the Solicitors Acts 1954-2011 [9022/DT120/12 and 2013 no 115SA] Law Society of Irela…

  • Robert Andrew Schofield
    SDT solicitor 11322/2014 2014-01-01 text match

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Adrian Patrick Shaun Dann
    SDT solicitor 11213/2014 2014-01-01 found breached text match

    Breaches, Failures, Others, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Robert Andrew Schofield
    SDT solicitor 11322/2014 2014-01-01 found breached text match

    Breaches, Failures

    Strike off 1 PDF View decision
  • Karen Louisa KING
    LSC-QLD solicitor K L King and Associates 2013-11-20 found breached text match

    Guilty of professional misconduct on 2 charges. Guilty of unsatisfactory professional conduct on 2 charges.

    other 1 PDF View decision
  • Autore, Anthony
    OLSC solicitor Autore & Associates 2013-11-15 text match

    Breach of undertaking - failure to respond to the OLSC — A reasonable likelihood of a finding of unsatisfactory professional conduct

    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
  • Woodbridge, Dean Joseph
    OLSC solicitor Clinch Long Letherbarrow Pty Ltd 2013-10-18 text match

    1. Breach of Rule 31 -Communicating with another solicitors client 2. Fail to comply with an undertaking — A reasonable likelihood of a finding of unsatisfactory professional conduct

    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
  • Siourounis, Constantine John
    OLSC solicitor Nexon Asia Pacific Pty Ltd 2013-09-19 text match

    1. Failure to comply with undertaking 2. Failure to comply with PC condition — A reasonable likelihood of a finding of unsatisfactory professional conduct

    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
  • Angelovski, Lupco Vanchov
    OLSC solicitor (Formerly) B J Murphy Angelovski & Associates|(Formerly) Morgan Ardino & Co [2013] NSWADT 93 2013-05-02 text match

    1. Failed to attend court to instruct Counsel when instructed to do so and when in receipt of a grant of Legal Aid to so attend 2. Failed to act in accordance with Legal Aid Practice Standards 3. Recklessly misled the O…

    Additional Orders made by the Tribunal (see Tribunal decision) Reprimand $0.00 Proceedings Instituted View decision
  • Brian Johnston
    LSI solicitor Brian Johnston & Co, Solicitors, 79 Park Street, Dundalk, Co Louth 2013-04-11 found breached

    In the matter of Brian Johnston, a solicitor formerly practising as Brian Johnston & Co, Solicitors, 79 Park Street, Dundalk, Co Louth, and in the matter of the Solicitors Acts 1954-2008 [6927/DT95/11 and High Court rec…

    strike_off View decision
  • Flynn, Mark Joseph
    OLSC solicitor (Formerly) Mark Flynn & Associates Pty Ltd [2013] NSWADT 70 2013-04-03 found breached text match

    Professional Misconduct: 1. Produced false trust account records 2. Breached his written undertaking 3. Attempted to mislead client's former solicitor 4. Failed to comply with undertaking dated 8 December 2008 5. Commun…

    Costs Removal of practitioner's name from the Roll of Local Lawyers $0.00 Proceedings Instituted View decision
  • Seamus P McConnell
    LSI solicitor Tullamore, Co Offaly 2013-01-28 found breached text match

    In the matter of Seamus P McConnell, solicitor, of Tullamore, Co Offaly, and in the matter of the Solicitors Acts 1954-2008 [6626/DT83/11, 6626/DT84/11 and High Court record 2012 no 87SA] Law Society of Ireland (applica…

    conditions View decision
  • James Hu
    LSBC lawyer 2013-01-24 found breached

    Agreed Statement of Facts

    Agreed Statement of Facts 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.