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discipline 30 September 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

  • Andrew Lindsay & Marina Frankel
    SDT solicitor 11576/2016 2016-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off, Suspend - Indefinite 1 PDF View decision
  • Michael John Elsdon
    SDT solicitor 11503/2016 2016-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Rajeswary Ramasamy
    SDT solicitor 11570/2016 2016-01-01 found breached

    Breaches

    Strike off 1 PDF View decision
  • Michael Davis
    SDT solicitor 11558/2016 2016-01-01 found breached

    Breaches

    S.43 Order (clerks) 1 PDF View decision
  • David Smith
    SDT solicitor 11499/2016 2016-01-01 found breached

    Breaches, Client Money, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Paul Stott
    SDT solicitor 11400/2016 2016-01-01 found breached

    Breaches, Failures

    Strike off 1 PDF View decision
  • Melvin Douglas Goldberg
    SDT solicitor 11464/2016 2016-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Gerard Tierney
    SSDT solicitor Gerard Tierney, formerly of G Tierney & Co, Boswell Legal Chambers, 189 Main Street, Auchinleck and presently residing at 13 Park Avenue, Prestwick 2015-12-16 found breached
    strike_off No Appeal 1 PDF View decision
  • Sue Machelle JOHNSTON
    LSC-QLD solicitor SJ Law 2015-12-15 found breached

    Guilty of professional misconduct on 9 charges. Guilty of unsatisfactory professional misconduct on 2 charges.

    other 1 PDF View decision
  • George Raymond Morton
    SSDT solicitor George Raymond Morton, Solicitor, formerly of Marshall Wilson Law Group Limited, 2 High Street, Falkirk and Morton Pacitti LLP, 5 Newmarket Street, Falkirk 2015-11-23 found breached
    strike_off No Appeal 1 PDF View decision
  • Alexander Gibbons
    LSI solicitor Gibbons & Co, 2 Riverside, Kent Street, Clonakilty, Co Cork 2015-10-19 found breached

    In the matter of Alexander Gibbons, a solicitor formerly practising as Gibbons & Co, 2 Riverside, Kent Street, Clonakilty, Co Cork, and in the matter of the Solicitors Acts 1954-2011 [5839/DT119/12; 5839/DT147/12; 5839/…

    strike_off View decision
  • Peter Kenny
    LSI solicitor Kenny Associates, College Street, Carlow, Co Carlow 2015-07-20 found breached

    In the matter of Peter Kenny, a solicitor formerly practising as Kenny Associates, College Street, Carlow, Co Carlow, and in the matter of the Solicitors Acts 1954-2011 [8864/DT61/14 and High Court record 2015 no 71 SA]…

    strike_off View decision
  • Raymond St John O’Neill
    LSI solicitor Raymond St J O’Neill & Co, 27/29 Washington Street, Cork 2015-07-20 found breached

    In the matter of Raymond St John O’Neill, a solicitor practising under the style and title of Raymond St J O’Neill & Co, 27/29 Washington Street, Cork, and in the matter of the Solicitors Acts 1954-2011 [3138/DT143/11; …

    conditions View decision
  • Elizabeth M Cazabon
    LSI solicitor Cazabon Solicitors, Gray Office Park, Galway Retail Park, Headford, Co Galway 2015-07-20 found breached

    In the matter of Elizabeth M Cazabon, a solicitor of Cazabon Solicitors, Gray Office Park, Galway Retail Park, Headford, Co Galway, and in the matter of the Solicitors Acts 1954-2011 [8142/DT05/14, 8142/DT22/14, 8142/DT…

    strike_off View decision
  • Peter Kenny
    LSI solicitor Kenny Associates, College Street, Carlow, Co Carlow 2015-07-20 found breached

    In the matter of Peter Kenny, a solicitor formerly practising as Kenny Associates, College Street, Carlow, Co Carlow, and in the matter of the Solicitors Acts 1954-2011 [8864/DT109/14 and High Court record 2015 no 70 SA…

    strike_off View decision
  • Paul Madden
    LSI solicitor Paul Madden & Company, Solicitors, Fitzpatrick Square, Clones, Co Monaghan 2015-06-22 found breached

    In the matter of Paul Madden, a solicitor formerly practising as Paul Madden & Company, Solicitors, Fitzpatrick Square, Clones, Co Monaghan, and in the matter of the Solicitors Acts 1954-2011 [10035/DT205/13 and High Co…

    strike_off View decision
  • Kevin M O'Gara
    LSI solicitor Unit 4, Level 1, the Reeks Gateway, Killarney, Co Kerry 2015-06-08 found breached

    In the matter of Kevin M O'Gara, solicitor, formerly practising as Kevin O'Gara, Unit 4, Level 1, the Reeks Gateway, Killarney, Co Kerry, and in the matter of the Solicitors Acts 1954-2011 [8391/DT129/13 and High Court …

    strike_off View decision
  • Craig Andrew Fraser
    SSDT solicitor Craig Andrew Fraser, Solicitor, residing at 70 Kennedy Crescent, Tranent 2015-05-22 found breached
    strike_off No Appeal 1 PDF View decision
  • Donald Alexander Gittens
    GLC attorney 8 of 2013 2015-04-22 found breached

    Reprimanded | Disciplinary Committee decision delivered April 22, 2015. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO: 8/2013 IN THE MATTER OF INDRA BAHADUR and DONALD GITTENS…

    Reprimanded 1 PDF View decision
  • O'donnell, Bernard Kevin
    OLSC solicitor K P O'Donnell & Associates [2015] NSWCATOD 17 2015-03-20 found breached

    1. Improperly charging fees for acting as Attorney & Enduring Guardian 2. Misappropriation 3. Breaching rule 12 of the Solicitors Rules 4. Misleading the Guardianship Tribunal 5. Falsely informing the Law Society and a …

    Costs Removal of practitioner's name from the Roll of Local Lawyers $0.00 Proceedings Instituted 1 PDF View decision
  • James J Maher
    LSI solicitor James Maher & Co, Solicitors, 1 The Bookend, Essex Quay, Dublin 8 2015-03-16 found breached

    In the matter of James J Maher, solicitor, practising as James Maher & Co, Solicitors, 1 The Bookend, Essex Quay, Dublin 8, and in the matter of the Solicitors Acts 1954-2008 [6676/DT82/12 and High Court record 2015/4SA…

    suspension View decision
  • John A Tobin
    LSI solicitor John A Tobin Solicitors, Level 3 Cornmarket, Robert Street, Limerick 2015-02-13 found breached

    In the matter of John A Tobin, solicitor, practising as John A Tobin Solicitors, Level 3 Cornmarket, Robert Street, Limerick, and in the matter of an application by the Law Society of Ireland to the Solicitors Disciplin…

    strike_off View decision
  • Evol W. Lyn-Cook
    GLC attorney 162 of 2002 2015-01-28 found breached

    Fined | Disciplinary Committee decision delivered January 28, 2015. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO: 162/2002 IN THE MATTER OF PATRICK STEPHENS and EVOL LYN COOK…

    Fined 1 PDF View decision
  • David Walsh
    LSI solicitor David Walsh & Co, Solicitors, 12 Mount Street, Mullingar, Co Westmeath 2015-01-12 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/DT134/12 and High Court…

  • David Walsh
    LSI solicitor David Walsh & Co, Solicitors, 12 Mount Street, Mullingar, Co Westmeath 2015-01-12 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/DT168/13 and High Court…

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.