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discipline 3 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.

505 cases 43% strike-off avg suspension 15.0 mo avg fine 83,213 198 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 28 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 198 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 37 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 6 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

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

  • 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
  • Thorpe, Terrance William
    OLSC barrister Sir Owen Dixon Chambers [2020] NSWCATOD 133 2020-11-24 found breached

    Ground 1: Breached Rule 62 of the Bar Rules when he failed to inform the defence representatives, or the Court: (a) of the fact that a key prosecution witness said at a witness conference, attended by the Respondent on …

    Reprimand $0.00 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
  • 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
  • Leslie, James Edward
    OLSC solicitor Leslie Hargrave Pty Ltd [2020] NSWCATOD 81 2020-07-23 found breached

    Ground 1: Caused a deficiency in the trust account Ground 2: Misappropriated trust funds Ground 3: Manipulated trust accounting records to conceal misappropriation of trust money Ground 4: Breaches of trust account obli…

    Order recommending removal of lawyer's name from the Roll of Australian Lawyers $0.00 1 PDF View decision
  • James Beresford Loel
    LSC-QLD solicitor Lilas & Loel Lawyers 2020-07-15 found breached

    On each of Charges 11, 13, 14, 15 and 17, there is a finding that the respondent engaged in professional misconduct. On each of Charges 1, 2, 3, 4, 5, 6, 7 and 10, there is a finding that the respondent engaged in unsat…

    Suspended 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
  • Glen Cameron Tedham
    LSBC lawyer 2020-01-30 found breached

    Rule 4-29 Admission of Misconduct and Undertaking

    Rule 4-29 Admission of Misconduct and Undertaking 1 PDF View decision
  • Daniel Lloyd Williams
    SDT solicitor 12103/2020 2020-01-01 found breached
    Variation of Conditions on Practising Certificate 1 PDF View decision
  • Martin Keith Waters & Rodney William Noon
    SDT solicitor 12101/2020 2020-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off, Suspend - Fixed Period 1 PDF View decision
  • Chidi Umezurike
    SDT solicitor 12112/2020 2020-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Gillian Margaret Walker
    SDT solicitor 12095/2020 2020-01-01 found breached

    Breaches

    S.43 Order (clerks) 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
  • 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
  • Kenneth M. McLeod
    GLC attorney 228 of 2018 2019-10-26 found breached

    Struck off | Disciplinary Committee decision delivered October 26, 2019. || Formal Order View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF THE GENERAL LEGAL COUNCIL COMPLAINT NO: 228/2018 IN THE MATTER OF LOWEL MORGAN,…

    Struck off 2 PDFs View decision
  • Kevin Frederick MacPherson
    SSDT solicitor Kevin Frederick MacPherson, Ravenswood House, PO Box 9945, Stornoway, Isle of Lewis 2019-10-22 found breached
    strike_off Appeal Concluded 2 PDFs View decision
  • Maurice B O’Sullivan
    LSI solicitor Maurice O’Sullivan & Company Solicitors, 9 Colbert Street, Listowel, Co Kerry 2019-10-14 found breached

    In the matter of Maurice B O’Sullivan, a solicitor practising as Maurice O’Sullivan & Company Solicitors, at 9 Colbert Street, Listowel, Co Kerry, and in the matter of the Solicitors Acts 1954-2015 [2017/DT24, 2017/DT38…

    strike_off View decision
  • James Edward Turner
    LSBC lawyer 2019-09-26 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.