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discipline 1 October 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

  • Sonia Sukhdeesh Hayer
    LSBC lawyer 2021-03-05 found breached

    Rule 3-7.1 Consent Agreement | Summary

    Rule 3-7.1 Consent Agreement | Summary 1 PDF View decision
  • Godwin Okri
    BTAS barrister Lincoln's Inn 2021-03-01 found breached
    Final 2 PDFs View decision
  • Femida Jamali
    SDT solicitor 12205/2021 2021-01-01 found breached

    Breaches, Failures

    Strike off 1 PDF View decision
  • David Ellis
    SDT solicitor 12193/2021 2021-01-01 found breached

    Breaches, Failures

    Strike off 1 PDF View decision
  • Briana Christine Ioannides
    LSC-QLD solicitor 2020-12-17 found breached

    Guilty of professional misconduct

    Struck off 1 PDF View decision
  • David Wayne Hadley
    LSC-QLD solicitor Essen Lawyers 2020-11-26 found breached

    In respect of charges 1, 2 and 4, the respondent engaged in professional misconduct. In respect of charge 3, the respondent engaged in unsatisfactory professional conduct.

    Suspended 1 PDF View decision
  • Christopher James Rosser
    LSC-QLD barrister 2020-10-20 found breached

    On each of Charges 1, 3, 4, 5, 9, 10 and 11 the respondent engaged in professional misconduct

    Struck off 1 PDF View decision
  • Rudolph Emanuel Alphonso Muir
    GLC attorney 200 of 2017 2020-09-30 found breached

    Suspended, Fined | Disciplinary Committee decision delivered September 30, 2020. View Formal Order Below View PDF of Decision View PDF of Formal Order DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL …

    Suspended, Fined 2 PDFs View decision
  • Maurice Frankson
    GLC attorney 243 of 2018 2020-08-13 found breached

    Suspended, Fined | Disciplinary Committee decision delivered August 13, 2020. || Guilty of Professional Misconduct | Disciplinary Committee decision delivered July 04, 2020. View PDF DECISION OF THE DISCIPLINARY COMMITT…

    Suspended, Fined 1 PDF View decision
  • John Anthony Greenhalgh
    LSC-QLD solicitor Greenhalgh Pickard Solicitors and Accountants 2020-07-24 found breached

    In respect of Charge 1, there is a finding that the respondent engaged in unsatisfactory professional conduct. In respect of Charge 2, there is a finding that the respondent engaged in professional misconduct.

    Other 1 PDF View decision
  • KEVIN COLIN BENEDICT STAFFA
    LPBWA lawyer PO Box 714 SUBIACO WA 6904 Legal Profession Complaints Committee v Staffa [2020] WASAT 2020-06-02 found breached

    Professional Misconduct and Unsatisfactory Professional Conduct

    Professional Misconduct and Unsatisfactory Professional Conduct 2 PDFs View decision
  • David Allen Kidd
    LSBC lawyer 2020-05-27 found breached

    Rule 4-29 Admission of Misconduct and Undertaking to Discipline Committee | Summary

    Rule 4-29 Admission of Misconduct and Undertaking to Discipline Committee | Summary 1 PDF View decision
  • CHRISTINA MARIE CHANG
    LPBWA lawyer Unit 4, Second Floor 108 Wanneroo Road TUART HILL WA 6060 Legal Profession Complaints Committee v Chang [2019] WASAT 67 (S) 2020-05-15 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 2 PDFs View decision
  • HELEN MARIE TOLSON
    LPBWA lawyer PO Box 3050 EAST PERTH WA 6892 Legal Profession Complaints Committee v Tolson [2020] WASC 2020-05-12 found breached

    Struck Off the Roll of Practitioners

    Struck Off the Roll of Practitioners 1 PDF View decision
  • Ek, Sawathey
    OLSC solicitor E K Lawyers 2020-04-16 text match

    1. Made unfounded allegations against the complainant 2. Continued to make allegations of misleading conduct against the complainant without any proper basis to do so — Unsatisfactory Professional Conduct

    Practitioner to undertake and complete further legal education 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
  • Konrad Malik
    LSBC lawyer 2020-03-30 found breached

    Rule 4-29 Admission of Conduct and Undertaking to Discipline Committee | Summary

    Rule 4-29 Admission of Conduct and Undertaking to Discipline Committee | Summary 1 PDF View decision
  • Jasmine Dominic
    LSC-QLD solicitor Enlightened Justice 2020-03-27 found breached

    The respondents conduct constitutes professional misconduct.

    Struck off 1 PDF View decision
  • Nicholas Peter Whiffen
    SDT solicitor 12116/2020 2020-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Sarah Lesley Watson
    SDT solicitor 12061/2020 2020-01-01 found breached

    Breaches, Solicitors' Accounts Rules

    Suspend - Fixed Period 1 PDF View decision
  • Edward Anthony Bromet
    SDT solicitor 12048/2020 2020-01-01 found breached

    Breaches

    Strike off 1 PDF View decision
  • Ivan John Poole
    LSC-QLD solicitor Ivan Poole Lawyers 2019-12-19 found breached rule cited

    Charges 1 and 4 the respondent's conduct amounts to professional misconduct. Charges 2 and 3 the respondent's conduct amounts to unsatisfactory professional conduct.

    Suspended 1 PDF View decision
  • Mark Lorrell
    BTAS barrister Lincoln's Inn 2019-11-13 found breached
    suspension Final 2 PDFs View decision
  • Howard A. Lettman
    GLC attorney 215 of 2017 2019-11-13 found breached

    Struck off, Restitution Ordered | Disciplinary Committee decision delivered November 13, 2019. || Guilty of Professional Misconduct | Disciplinary Committee decision delivered July 20, 2019. View PDF View Formal Order D…

    Struck off, Restitution Ordered 2 PDFs View decision
  • Lee Sowden
    BTAS barrister Middle Temple 2019-11-11 found breached
    Final 2 PDFs View decision
  • Baldev Singh Ghag
    LSBC lawyer 2019-11-04 found breached

    Rule 4-29 Admission of Misconduct and Undertaking | Summary

    Rule 4-29 Admission of Misconduct and Undertaking | 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.