Skip to main content
discipline 4 October 2026

The duty in context

No improper use of client money money

The lawyer must withdraw client money only for its proper purpose, must not overdraw a client's funds, and must not use the client account as a banking facility.

1,577 cases 67% strike-off avg suspension 14.0 mo avg fine 62,331 864 with dishonesty finding

How the codes express this duty

E&W Solicitors SRA Principles & Code SAR Rule 5.1; SAR Rule 3.3; SAR Rule 5.3 strong 1,062 cases
5.1 You only withdraw client money from a client account: (a) for the purpose for which it is being held; ... 3.3 You must not use a client account to provide banking facilities to clients or third parties. ... 5.3 You only withdraw client money from a client account if sufficient funds are held on behalf of that specific client or third party to make the payment.
E&W Barristers BSB Handbook no clear equivalent
Cayman Islands Legal Services Code 2026 P.7; R.9.2 partial
Attorneys-at-law shall protect client money and assets... An attorney-at-law and a recognised law entity shall safeguard money and assets entrusted to them by clients and others.
AU Solicitors Solicitors' Conduct Rules no clear equivalent
AU Barristers Uniform Barristers Rules no clear equivalent
IE Solicitors Law Society Guide Ch9 — Accounts regulations: General strong 90 cases
To use each client's money for that client's matter only, To use trust money only for the purpose of that trust... To establish and maintain proper accounting systems and proper internal control systems to ensure compliance with the regulations.
IE Barristers Bar Code of Conduct no clear equivalent
JM Attorneys Canons of Professional Ethics Canon VII(a) partial 137 cases
An Attorney shall comply with rules as may from time to time be prescribed by the General Legal Council relating to the keeping in separate accounts- (i) the funds of himself or any firm with which he is associated; and (ii) those of his clients.
JE Lawyers Law Society of Jersey Code P.7; R.7.4 a),c) partial
Members must protect client money and assets... Members must: a) identify, monitor and manage risks to money and assets entrusted to them by clients and others... c) ensure compliance with the Accounts Rules.
ON Lawyers LSO Rules of Prof. Conduct r 3.6-10; r 3.2-7.3 strong
3.6-10 A lawyer shall not appropriate any funds of the client held in trust or otherwise under the lawyer's control for or on account of fees except as permitted by the by-laws under the Law Society Act. [3.2-7.3 A lawyer shall not use their trust account for purposes not related to the provision of legal services.]
BC Lawyers BC Code r 3.6-10 strong 66 cases
A lawyer must not appropriate any client funds held in trust or otherwise under the lawyer's control for or on account of fees, except as permitted by the governing legislation.
NZ Lawyers Conduct & Client Care Rules r 10.5.2 / r 9.3 partial
A lawyer who receives funds on terms requiring the lawyer to hold the funds in a trust account as a stakeholder must adhere strictly to those terms and disburse the funds only in accordance with them. ... A lawyer who wishes to debit fees held in trust or to receive funds to cover fees in advance must comply with the requirements of regulations 9 and 10 of the Lawyers and Conveyancers Act (Trust Account) Regulations 2008.
SCO Solicitors LSS Standards of Conduct no clear equivalent
SG Lawyers Professional Conduct Rules 2015 r 16 (Client money) partial 23 cases
16 Client money
HK Solicitors Solicitors' Guide Principle 13.02 / Principle 4.02 Commentary 4 partial
A client account cheque must never be dishonoured. A solicitor must take care to ensure that any cheque for use in connection with his practice will be honoured upon presentation. ... Dishonour of a client account cheque will other than in exceptional circumstances indicate a breach of the Solicitors' Accounts Rules (Cap. 159 sub. leg. F). ... Under rule 9(2) of the Solicitors' Accounts Rules (Cap. 159 sub. leg. F), money received for or on account of an agreed fee which is paid by a client to his solicitor must be paid into an office account.
HK Barristers Bar Code of Conduct no clear equivalent

Cases dealing with this duty

Clear

1,577 decisions · link basis: found breached = a tribunal finding; rule cited = the mapped provision is cited in the decision; text match = high-precision text pattern

  • Christopher Lynch
    LSI solicitor Christopher Lynch Solicitors, 99 O’Connell Street, Limerick 2014-07-07 found breached

    In the matter of Christopher Lynch, a solicitor previously practising as Christopher Lynch Solicitors at 99 O’Connell Street, Limerick, and in the matter of the Solicitors Acts 1954-2011 [8386/DT72/13 and High Court rec…

    suspension 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

    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/DT20/12 and 2014 no 39 …

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

    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/DT41/10 and 2014 no 37 …

    strike_off View decision
  • Downie, Daniel Mcgregor
    OLSC solicitor (Formerly) Downie & Co [2014] NSWCATOD 60 2014-05-23 found breached

    1. Breaches of Section 255 LPA 2004 - disbursing trust money without authority 2. Breaches of Section 264 LPA 2004 - failing to keep trust records in a way that discloses true position 3. Misappropriation 4. Causing a d…

    Costs Removal of practitioner's name from the Roll of Local Lawyers $0.00 View decision
  • Christopher William Hales
    SSDT solicitor Christopher William Hales, 74/1 Spottiswoode Street, Edinburgh 2014-05-13 found breached
    strike_off No Appeal 1 PDF View decision
  • Daniel Downes
    LSI solicitor O’Dea & Company, Solicitors, 1st Floor, Hardiman House, Eyre Square, Galway 2014-04-28 found breached

    In the matter of Daniel Downes, a solicitor formerly practising as O’Dea & Company, Solicitors, at 1st Floor, Hardiman House, Eyre Square, Galway, and in the matter of the Solicitors Acts 1954-2011 [4298/DT150/12 and Hi…

    strike_off View decision
  • Aiden Barry
    LSI solicitor Aiden Barry Solicitor, Roche House, 8 Bank Place, Limerick, Co Limerick 2014-04-28 found breached

    In the matter of Aiden Barry, solicitor, formerly practising as Aiden Barry Solicitor, Roche House, 8 Bank Place, Limerick, Co Limerick, and in the matter of the Solicitors Acts 1954-2011 [7243/DT59/13 and High Court re…

    strike_off View decision
  • Elizabeth McGrath
    LSI solicitor O’Connell McGrath Solicitors, 5 Athlunkard Street, Limerick 2014-04-28 found breached

    In the matter of Elizabeth McGrath,a solicitor formerly practising as O’Connell McGrath Solicitors, 5 Athlunkard Street, Limerick, and in the matter of the Solicitors Acts 1954-2011 [11016/DT118/12 and High Court record…

    strike_off View decision
  • Aiden Barry
    LSI solicitor Aiden Barry Solicitor, Roche House, 8 Bank Place, Limerick, Co Limerick 2014-04-28 found breached

    In the matter of Aiden Barry, solicitor, formerly practising as Aiden Barry Solicitor, Roche House, 8 Bank Place, Limerick, Co Limerick, and in the matter of the Solicitors Acts 1954-2011 [7243/DT96/13 and High Court re…

    strike_off View decision
  • Denise McNulty
    LSI solicitor Denise McNulty & Co, Solicitors, Zion Court, Zion Church Grounds, Rathgar, Dublin 6 2014-03-10 found breached

    In the matter of Denise McNulty, solicitor, practising as Denise McNulty & Co, Solicitors, Zion Court, Zion Church Grounds, Rathgar, Dublin 6, and in the matter of the Solicitors Acts 1954-2011 [4457/DT113/13 and High C…

    conditions View decision
  • Elsie A. Taylor
    GLC attorney 175 of 1996 2014-02-10 found breached

    Repayment Ordered | Disciplinary Committee decision & Review delivered November 28, 2003. | Decision affirmed on appeal View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL Complaint# 175 of 1996…

    Repayment Ordered 1 PDF View decision
  • Michele O'Keeffe
    LSI solicitor Michele O’Keeffe & Company, 1 Cornmarket Street, Ennis, Co Clare 2014-01-13 found breached

    In the matter of Michele O’Keeffe, a solicitor previously practising as Michele O’Keeffe & Company, 1 Cornmarket Street, Ennis, Co Clare, and in the matter of the Solicitors Acts 1954-2011 [8246/DT151/12 and 2013 no 109…

    strike_off View decision
  • John Kilraine
    LSI solicitor Kilraine & Company, Solicitors, Nile Lodge Corner, Galway 2014-01-13 found breached

    In the matter of John Kilraine, a solicitor previously practising as Kilraine & Company, Solicitors, at Nile Lodge Corner, Galway, and in the matter of the Solicitors Acts 1954-2011 [6868/DT81/12 and 2013 no 103SA] Law …

    strike_off View decision
  • Adrian Patrick Shaun Dann
    SDT solicitor 11213/2014 2014-01-01 found breached

    Breaches, Failures, Others, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Stephen Jackson
    SDT solicitor 11296/2014 2014-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Russell James Rollings
    SDT solicitor 11219/2014 2014-01-01 found breached text match

    Breaches, Client Money, Others, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Guy Richard Charles Bailey
    SDT solicitor 11267/2014 2014-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Suspend - Indefinite 1 PDF View decision
  • Richard Arnold Wilkes
    SDT solicitor 11281/2014 2014-01-01 found breached text match

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Tom Jenkins Merralls
    SDT solicitor 11309/2014 2014-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Louis Stanley Spragg
    SDT solicitor 11216/2014 2014-01-01 found breached text match

    Breaches, Failures, Others

    Strike off 1 PDF View decision
  • Mark Pearson Ford
    SDT solicitor 11272/2014 2014-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Neil Lawrence Jacobsen
    SDT solicitor 11240/2014 2014-01-01 found breached text match

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Richard Anthony Barnett & Another
    SDT solicitor 11249/2014 2014-01-01 found breached

    Breaches, Others

    Strike off, Suspend - Fixed Period 1 PDF View decision
  • Neil Lawrence Jacobsen
    SDT solicitor 11240/2014 2014-01-01 found breached text match

    Breaches, Client Money, Others, Solicitors' Accounts Rules

    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.