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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

  • Neal Simmons
    SDT solicitor 11017/2012 2012-01-01 found breached

    Breaches, Criminal Convictions

    Strike off 1 PDF View decision
  • Neal Simmons
    SDT solicitor 11017/2012 2012-01-01 found breached

    Criminal Convictions

    Strike off 1 PDF View decision
  • Simon William Griffiths
    SDT solicitor 11100/2012 2012-01-01 found breached

    Breaches, Client Money, Failures, Others, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Kathleen Chadwick & 2 Others
    SDT solicitor 11013/2012 2012-01-01 found breached text match

    Breaches, Client Money, Failures, Solicitors' Accounts Rules, Others

    Fine, S.43 Order (clerks), Strike off 1 PDF View decision
  • James Campbell Kilpatrick
    SDT solicitor 10906/2012 2012-01-01 found breached

    Breaches, Others

    Strike off 1 PDF View decision
  • I A V Pratchett, M Obeng & A Das
    SDT solicitor 10958/2012 2012-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Prohibition Order, Strike off, Suspend - Fixed Period, Variation of Conditions on Practising Certificate 1 PDF View decision
  • Basharat Ali Ditta
    SDT solicitor 11060/2012 2012-01-01 found breached

    Criminal Convictions

    Strike off 1 PDF View decision
  • Anthony Robert Bogan
    SDT solicitor 10973/2012 2012-01-01 found breached

    Breaches, Others

    Strike off 1 PDF View decision
  • Paul Sohal
    SDT solicitor 11036/2012 2012-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules, Others

    Strike off 1 PDF View decision
  • Krama & Co
    SDT solicitor 11025/2012 2012-01-01 found breached

    Breaches, Failures, Others

    S.43 Order (clerks) 1 PDF View decision
  • Hugh Abel Levy
    GLC attorney 2011-12-03 found breached rule cited

    Fined | Disciplinary Committee decision delivered December 03, 2011. View PDF DECISION Complaints: 180/98 Mernel Cox vs. Hugh Levy 181/98 Yvonne Forbes vs. Hugh Levy 197/98 Pearl McLaren vs. Hugh Levy Mr. Donald Scharsc…

    Fined 1 PDF View decision
  • TRICIA Y. BACHMANN
    LPBWA lawyer PO Box 1502 SOUTH PERTH WA 6951 Legal Profession Complaints Committee v Bachmann [2011] WASC 309 2011-11-15 found breached

    Struck Off the Roll of Practitioners

    Struck Off the Roll of Practitioners 1 PDF View decision
  • Anthony David Murphy
    SSDT solicitor Antony David Murphy formerly of 31 Chapel Street, Hamilton. Lanarkshire now of 3 Chateau Grove, Hamilton, Lanarkshire 2011-09-14 found breached
    strike_off No Appeal 1 PDF View decision
  • CARMEL MARY FITZPATRICK
    LPBWA lawyer PO Box 812 MANDURAH WA 6210 Legal Profession Complaints Committee v Fitzpatrick [2011] WASC 320 2011-08-30 found breached

    Struck Off the Roll of Practitioners

    Struck Off the Roll of Practitioners 1 PDF View decision
  • Peter Ross CLAPIN
    LSC-QLD solicitor N/A 2011-07-21 found breached

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

    other 1 PDF View decision
  • Charles O'Neill
    LSI solicitor Cathal O'Neill & Company, Solicitors, 10 Church Avenue, Rathmines, Dublin 6 2011-06-27 found breached

    In the matter of Charles O’Neill, a solicitor formerly practising as Cathal O’Neill & Company, Solicitors, 10 Church Avenue, Rathmines, Dublin 6, and in the matter of the Solicitors Acts 1954-2008 [2707/DT81/09 and High…

    strike_off View decision
  • Peter McGarry
    LSI solicitor Peter McGarry & Co, Solicitors, 27 Capel Street, Dublin 1 2011-05-30 found breached

    In the matter of Peter McGarry, a solicitor, formerly practising as Peter McGarry & Co, Solicitors, 27 Capel Street, Dublin 1, and in the matter of the Solicitors Acts 1954-2008 [4989/DT02/11 and High Court record no 20…

    strike_off View decision
  • Mr Thong Sum LEE
    LSNT lawyer 25 Lindsay St, Darwin NT 0800 (former) 2011-05-07 found breached

    Findings of professional misconduct Reasons for decision

    Public reprimand Fine of $10,000.00 1 PDF View decision
  • SALLY MARJORIE VANDERFEEN
    LPBWA lawyer PO Box 9991 PERTH WA 6848 Legal Profession Complaints Committee v Vanderfeen [2011] WASAT 118 and [2011] WASAT 118 (S) 2011-04-27 found breached

    Professional Misconduct

    Professional Misconduct 2 PDFs View decision
  • PAUL ERNEST MASTEN
    LPBWA lawyer Suite 2 and Suite 11 16 Philimore Street FREMANTLE WA 6166 Legal Profession Complaints Committee v Masten [2011] WASC 2011-04-27 found breached

    Struck Off the Roll of Practitioners

    Struck Off the Roll of Practitioners 1 PDF View decision
  • Peter Nicholas Arthur ROWLANDS
    LSC-QLD solicitor Peter Rowlands & Co 2011-04-06 found breached

    Guilty of professional misconduct on 10 charges. Guilty of unprofessional conduct on 2 charges.

    other 1 PDF View decision
  • Mark Victor Michie
    SSDT solicitor Mark Victor Michie, 25 Rosebery Street, Aberdeen 2011-03-09 found breached
    strike_off Appeal Concluded 1 PDF View decision
  • English, Martin Francis
    OLSC solicitor (Formerly) English Kearns (2004) 2011-03-02 found breached

    1. Breached an undertaking to the Legal Services Commissioner 2. Practised without a Practising Certificate 3. Failed to account 4. Wilfully breached Section 61 of the Legal Profession Act 1987 - handling of trust money…

    Conditions on Practising Certificate Costs Reprimand $0.00 View decision
  • Jermaine Ryan Simms
    GLC attorney 41 of 2009 2011-02-19 found breached

    Struck off, Restitution Ordered | Disciplinary Committee decision delivered February 19, 2011. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCILCOMPLAINT No. 41/2009 BETWEEN MARINE WILDLIFE PU…

    Struck off, Restitution Ordered 1 PDF View decision
  • Antonnette Haughton Cardenas
    GLC attorney 3 of 2010 2011-02-05 found breached

    Already Struck off | Disciplinary Committee decision delivered February 05, 2011. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO. 3 OF 2010 IN THE MATTER OF A COMPLAINT BY ISMO…

    Already Struck 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.