Decision record
Kanwar Bhan
Allegation / charges
Breaches, Client Money, Failures, Solicitors' Accounts Rules
Findings — machine-extracted (anthropic-batch:claude-opus-4-8); verify against the decision
Kanwar Bhan (First Respondent), sole owner of GS Law LLP, was found to have failed to keep accounting records, failed to carry out client reconciliations, made 55 improper round-sum transfers from client to office account leaving a minimum shortage of £104,753 which was never remedied, made misleading statements on a PII proposal form, acquiesced in a conveyancing transaction bearing hallmarks of mortgage fraud (leading to a £2.4m Compensation Fund claim), and appointed an unsuitable COFA. The Tribunal found he acted dishonestly (Twinsectra test) in using client money for the firm's and his own personal expenses, and struck him off, ordering £18,000 costs. The Second Respondent, who admitted all allegations, accepted the COFA role while unsuitable and failed to comply with it; she was reprimanded and ordered to pay £1,000 costs. The hearing proceeded in the First Respondent's absence.
Duties found breached:
- Proper basis for allegations
- Not mislead third parties or opponents
- No conflict between current clients
- Accounting records, reconciliation and reports
- Competence
Aggravating factors:
- Dishonesty found against the First Respondent
- Misconduct was a series of improper transfers over a period of months, not a momentary lapse
- Client account shortage of over £104,000 which was never replaced
- Use of client money for personal expenses (clothing, jewellery, restaurant, cash withdrawals)
- Involvement in a transaction with clear hallmarks of fraud leading to a £2.4m Compensation Fund claim
Mitigating factors:
- No previous disciplinary matters (both Respondents)
- For Second Respondent: inexperienced solicitor, inadequately supervised, no motivation or planning, no access to bank accounts, prompt full admissions and genuine insight, reliance on First Respondent who acted as mentor
Duties engaged
- Proper basis for allegations
- Cease acting on client perjury or disobedience
- Honesty
- Not mislead third parties or opponents
- No bribery or improper gifts
- Personal probity and fitness to practise
- Uphold public trust in the profession
- No unlawful discrimination or harassment
- Act in the client's best interests
- Advise objectively, not a mere conduit
- No conflict between current clients
- Accounting records, reconciliation and reports
- Competence
- Firm governance, systems and compliance