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discipline 1 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.

1,282 cases 61% strike-off avg suspension 17.6 mo avg fine 138,302 623 with dishonesty finding

How the codes express this duty

E&W Solicitors SRA Principles & Code CCS 6.2 strong 841 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 29 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 126 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 38 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 50 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 50 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 125 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 35 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 55 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 8 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

1,282 decisions · link basis: found breached = a tribunal finding; rule cited = the mapped provision is cited in the decision; text match = high-precision text pattern

  • Moray Charles Livingstone MacPherson
    SDT solicitor 10119/2008 2008-01-01 found breached

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

    Prohibition Order 1 PDF View decision
  • A J Nulty & Another
    SDT solicitor 9871/2008 2008-01-01 found breached

    Breaches, Others

    Fine, Strike off 1 PDF View decision
  • Derek John Leonard
    SDT solicitor 9896/2008 2008-01-01 found breached

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

    Strike off 1 PDF View decision
  • Colin D Poole
    SDT solicitor 10129/2008 2008-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules, Others

    Fine, Strike off 1 PDF View decision
  • Martin William Harrison
    SDT solicitor 9999/2008 2008-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Karl Phillips
    SDT solicitor 9979/2008 2008-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Timothy John Chapman
    SDT solicitor 9970/2008 2008-01-01 found breached

    Breaches, Client Money, Others

    Strike off 1 PDF View decision
  • Audrey Heslop-Mendez
    GLC attorney 14 of 2001 2007-09-07 found breached

    Restitution Ordered, Already Struck off | Disciplinary Committee decision delivered September 07, 2007. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO. 14/2001 In the Matter of…

    Restitution Ordered, Already Struck off 1 PDF View decision
  • Player, Ian Alexander
    OLSC solicitor (Formerly) Sole Principal of: Ian A Player Solicitor & Conveyancer [2007] NSWADT 191 2007-08-22 found breached

    1. Wilful breach of Section 61 of the Legal Profession Act, 1987 2. Misappropriation 3. Unethical conduct (a) omitting from returns lodged with the Office of State Revenue notifications of stamp duty payable; (b) falsel…

    Costs Removal of practitioner's name from the Roll of Local Lawyers $0.00 Proceedings Instituted 1 PDF View decision
  • Gray, Roger Winchester
    OLSC solicitor Grays Lawyers 2007-06-29 found breached

    1. Breached Section 61(3)(b) Legal Profession Act. 1987 - handling of trust moneys 2. Breached Clause 78 Legal Profession Regulation 2002 - 3. Breached Section 261(1)(b) Legal Profession Act, 2004 - dealing with trust m…

    Suspension of Practising Certificate $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
  • TOMAS MIJATOVIC
    LPBWA lawyer PO Box 298 LEEDERVILLE WA 6007 Legal Practitioners Complaints Committee v Mijatovic [2007] WASAT 111 and [2007] WASAT 111 (S) 2007-05-23 found breached

    Unprofessional Conduct and Suspended

    Unprofessional Conduct and Suspended 2 PDFs View decision
  • COLIN ROBERT McKERLIE
    LPBWA lawyer Level 1, 538 Hay Street PERTH WA 6000 Legal Practitioners Complaints Committee v McKerlie [2007] WASC 119 2007-05-21 found breached

    Struck Off the Roll of Practitioners

    Struck Off the Roll of Practitioners 1 PDF View decision
  • Russell Galt WALTERS
    LSC-QLD solicitor Walters & Co 2007-05-18 found breached

    Guilty of professional misconduct on 7 charges.

    other 1 PDF View decision
  • Stephen Joseph HOOLIHAN
    LSC-QLD solicitor S. J. Hoolihan & Associates 2007-04-18 found breached

    Guilty of professional misconduct on 21 charges Guilty of unsatisfactory professional conduct on 3 charges

    other 1 PDF View decision
  • Kennedy, Paul Herbert
    OLSC solicitor (Formerly) Kennedy & Associates [2007] NSWADT 59 2007-03-15 found breached

    1. The Solicitor breached Rule 12 of the Revised Conduct and Practice Rules dealing with borrowing transactions 2. Negligent in failing to secure registration of the second mortgage 3. Engaged in unethical conduct by br…

    Costs Removal of practitioner's name from the Roll of Local Lawyers $0.00 Proceedings Instituted 1 PDF View decision
  • Vosnakis, Joseph Con
    OLSC solicitor (Formerly) Vosnakis & Associates [2007] NSWADT 42 2007-01-23 found breached

    1. Failure to comply with a Notice under Section 152 of the Legal Profession Act 1987 2. Borrowed from clients in breach of Rule 12 of the Professional Conduct & Practice Rules 3. Failed to document the loans from clien…

    Costs Removal of practitioner's name from the Roll of Local Lawyers $0.00 Proceedings Instituted 1 PDF View decision
  • Muir, Brian Thomas Gregory
    OLSC solicitor Brian Muir 2007-01-18 found breached

    1. Breached Section 61 of the Legal Profession Act 1987 - handling of trust moneys 2. Breached Section 62 of the Legal Profession Act 1987 - keeping of trust accounts 3. Breached Section 255 of the Legal Profession Act …

    Suspension of Practising Certificate $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
  • Horace Okeroghene Onobrakpeya
    SDT solicitor 9752/2007 2007-01-01 found breached

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

    Strike off 1 PDF View decision
  • B O Okafor & O L Ohre-Emuobosa
    SDT solicitor 9676/2007 2007-01-01 found breached

    Client Money, Failures, Solicitors' Accounts Rules

    Strike off, Suspend - Fixed Period 1 PDF View decision
  • Julie Grant
    SDT solicitor 9798/2007 2007-01-01 found breached

    Others

    S.43 Order (clerks) 1 PDF View decision
  • G Okri & Another
    SDT solicitor 9736/2007 2007-01-01 found breached

    Breaches, Failures, Others

    Strike off, Suspend - Fixed Period 1 PDF View decision
  • M A Olaseinde & A M Hemming
    SDT solicitor 9742/2007 2007-01-01 found breached

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

    Strike off, Suspend - Indefinite 1 PDF View decision
  • Ellen Jayne Godsell
    SDT solicitor 9794/2007 2007-01-01 found breached

    Breaches, Client Money, Solicitors' Accounts Rules, Others

    Suspend - Indefinite 1 PDF View decision
  • Malcolm Reginald Brown
    SDT solicitor 9707/2007 2007-01-01 found breached

    Breaches, Client Money, Failures, Others

    Strike off 1 PDF View decision
  • Sudesh Chamba
    SDT solicitor 9788/2007 2007-01-01 found breached

    Breaches, Client Money, Delays, Failures, 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.