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discipline 30 September 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.

522 cases 43% strike-off avg suspension 11.5 mo avg fine 57,181 193 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 50 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 196 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 41 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 11 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

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

  • RICHARD JAMES LAWSON
    LPBWA lawyer 7 Wilberforce Street MOUNT HAWTHORN WA 6016 Legal Profession Complaints Committee and Lawson [2021] WASAT 152, Legal Profession Complaints Committee and Lawson [2021] WASAT 152 (S) 2021-11-30 found breached

    Professional Misconduct, referral to Supreme Court

    Professional Misconduct, referral to Supreme Court 2 PDFs View decision
  • Robert Glen Orris
    LSBC lawyer 2021-11-29 found breached

    Rule 3-7.1 Consent Agreement | Summary

    Rule 3-7.1 Consent Agreement | Summary 1 PDF View decision
  • 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
  • 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
  • Kevin Farquharson
    BTAS barrister Middle Temple 2021-10-21 found breached
    appeal allowed 1 PDF View decision
  • Glen Koh
    BTAS barrister Middle Temple 2021-10-20 found breached
    suspension Final 2 PDFs 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
  • Alison Hartvigsen
    LSC-QLD solicitor AMH Lawyers 2021-08-31 found breached

    Charges 1, 2, 3, 4, 5, 6, 7, 8, 9 and 10, there is a finding that the Respondent engaged in professional misconduct.

    Struck off 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 Proceedings Instituted 1 PDF View decision
  • Mohammed Uddin
    BTAS barrister Lincoln's Inn 2021-06-30 found breached
    Final 2 PDFs 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
  • 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
  • Stephen James Keliher
    LSC-QLD solicitor Milne Legal 2021-06-15 found breached

    Guilty of professional misconduct

    Struck off 1 PDF View decision
  • Kevin Manning
    BTAS barrister Middle Temple 2021-06-10 found breached
    strike_off Final 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
  • Paul Christopher Doroshenko
    LSBC lawyer 2021-04-28 found breached

    Rule 3-7.1 Consent Agreement | Summary

    Rule 3-7.1 Consent Agreement | Summary 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.