Skip to main content
discipline 4 October 2026

The duty in context

No improper use of client money money

The lawyer must withdraw client money only for its proper purpose, must not overdraw a client's funds, and must not use the client account as a banking facility.

1,577 cases 67% strike-off avg suspension 14.0 mo avg fine 62,331 864 with dishonesty finding

How the codes express this duty

E&W Solicitors SRA Principles & Code SAR Rule 5.1; SAR Rule 3.3; SAR Rule 5.3 strong 1,062 cases
5.1 You only withdraw client money from a client account: (a) for the purpose for which it is being held; ... 3.3 You must not use a client account to provide banking facilities to clients or third parties. ... 5.3 You only withdraw client money from a client account if sufficient funds are held on behalf of that specific client or third party to make the payment.
E&W Barristers BSB Handbook no clear equivalent
Cayman Islands Legal Services Code 2026 P.7; R.9.2 partial
Attorneys-at-law shall protect client money and assets... An attorney-at-law and a recognised law entity shall safeguard money and assets entrusted to them by clients and others.
AU Solicitors Solicitors' Conduct Rules no clear equivalent
AU Barristers Uniform Barristers Rules no clear equivalent
IE Solicitors Law Society Guide Ch9 — Accounts regulations: General strong 90 cases
To use each client's money for that client's matter only, To use trust money only for the purpose of that trust... To establish and maintain proper accounting systems and proper internal control systems to ensure compliance with the regulations.
IE Barristers Bar Code of Conduct no clear equivalent
JM Attorneys Canons of Professional Ethics Canon VII(a) partial 137 cases
An Attorney shall comply with rules as may from time to time be prescribed by the General Legal Council relating to the keeping in separate accounts- (i) the funds of himself or any firm with which he is associated; and (ii) those of his clients.
JE Lawyers Law Society of Jersey Code P.7; R.7.4 a),c) partial
Members must protect client money and assets... Members must: a) identify, monitor and manage risks to money and assets entrusted to them by clients and others... c) ensure compliance with the Accounts Rules.
ON Lawyers LSO Rules of Prof. Conduct r 3.6-10; r 3.2-7.3 strong
3.6-10 A lawyer shall not appropriate any funds of the client held in trust or otherwise under the lawyer's control for or on account of fees except as permitted by the by-laws under the Law Society Act. [3.2-7.3 A lawyer shall not use their trust account for purposes not related to the provision of legal services.]
BC Lawyers BC Code r 3.6-10 strong 66 cases
A lawyer must not appropriate any client funds held in trust or otherwise under the lawyer's control for or on account of fees, except as permitted by the governing legislation.
NZ Lawyers Conduct & Client Care Rules r 10.5.2 / r 9.3 partial
A lawyer who receives funds on terms requiring the lawyer to hold the funds in a trust account as a stakeholder must adhere strictly to those terms and disburse the funds only in accordance with them. ... A lawyer who wishes to debit fees held in trust or to receive funds to cover fees in advance must comply with the requirements of regulations 9 and 10 of the Lawyers and Conveyancers Act (Trust Account) Regulations 2008.
SCO Solicitors LSS Standards of Conduct no clear equivalent
SG Lawyers Professional Conduct Rules 2015 r 16 (Client money) partial 23 cases
16 Client money
HK Solicitors Solicitors' Guide Principle 13.02 / Principle 4.02 Commentary 4 partial
A client account cheque must never be dishonoured. A solicitor must take care to ensure that any cheque for use in connection with his practice will be honoured upon presentation. ... Dishonour of a client account cheque will other than in exceptional circumstances indicate a breach of the Solicitors' Accounts Rules (Cap. 159 sub. leg. F). ... Under rule 9(2) of the Solicitors' Accounts Rules (Cap. 159 sub. leg. F), money received for or on account of an agreed fee which is paid by a client to his solicitor must be paid into an office account.
HK Barristers Bar Code of Conduct no clear equivalent

Cases dealing with this duty

Clear

1,577 decisions · link basis: found breached = a tribunal finding; rule cited = the mapped provision is cited in the decision; text match = high-precision text pattern

  • Marcus Paul Nickson
    SDT solicitor 11436/2015 2015-01-01 found breached

    Breaches, Failures

    Strike off 1 PDF View decision
  • Deidre Dain Newell-Austin & Najma Nahid Assroundi & Rashad Ahsan
    SDT solicitor 11359/2015 2015-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off, Strike Off Register of Foreign Lawyers 1 PDF View decision
  • Dalida Rajeshree Jhugroo
    SDT solicitor 11455/2015 2015-01-01 found breached

    Breaches, Failures

    Strike off 1 PDF View decision
  • Timothy Charles Elkins
    SDT solicitor 11429/2015 2015-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Simon Michael Armitage
    SDT solicitor 11347/2015 2015-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Michael Lyons & Kelly Lyons
    SDT solicitor 11435/2015 2015-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    S.43 Order (clerks), Strike off 1 PDF View decision
  • Victoria Louise Robinson
    SDT solicitor 11426/2015 2015-01-01 found breached text match

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Stephen Allan Lawson
    SDT solicitor 11372/2015 2015-01-01 found breached text match

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • David Michael Merrick
    SDT solicitor 11385/2015 2015-01-01 found breached

    Breaches, Client Money, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Stephanie Berry
    SDT solicitor 11384/2015 2015-01-01 found breached

    Breaches, Client Money, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Premji Naran Patel
    SDT solicitor 11328/2015 2015-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Philip Crowe
    SDT solicitor 11335/2015 2015-01-01 found breached

    Client Money, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Sabir Hussain
    SDT solicitor 11414/2015 2015-01-01 found breached

    Breaches, Client Money, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Edgar Stephen George Thomas
    SDT solicitor 11373/2015 2015-01-01 found breached

    Breaches, Delays, Failures, Others

    Strike off 1 PDF View decision
  • Alan Blacker
    SDT solicitor 11428/2015 2015-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules, Others

    Strike off 1 PDF View decision
  • Rajesh Babajee
    SDT solicitor 11445/2015 2015-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Marie-Garrard Newton
    SDT solicitor 11375/2015 2015-01-01 found breached

    Breaches, Delays, Failures, Others, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • John Randall Slade
    SDT solicitor 11419/2015 2015-01-01 found breached text match

    Breaches, Client Money, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • GEOFFREY PAUL DUTTON
    LPBWA lawyer Level 1 195 Adelaide Terrace PERTH WA 6000 Legal Profession Complaints Committee v Dutton [2014] WASC 2014-12-04 found breached

    Struck Off the Roll of Practitioners

    Struck Off the Roll of Practitioners 1 PDF View decision
  • Niall O'Kelly
    LSI solicitor Niall O’Kelly Solicitors, 52 Fortfield Park, Terenure, Dublin 6W 2014-10-20 found breached

    In the matter of Niall O’Kelly, a solicitor previously practising as Niall O’Kelly Solicitors, 52 Fortfield Park, Terenure, Dublin 6W, and in the matter of the Solicitors Acts 1954-2011 [5202/DT156/12, 5202/DT11/13 and …

    strike_off View decision
  • Raffaele Crescenzo
    LSBC lawyer 2014-09-25 found breached

    Agreed Statement of Facts

    Agreed Statement of Facts 1 PDF View decision
  • GEOFFREY PAUL DUTTON
    LPBWA lawyer Level 1 195 Adelaide Terrace PERTH WA 6000 Legal Profession Complaints Committee v Dutton [2014] WASAT 2014-09-23 found breached

    Professional Misconduct

    Professional Misconduct 1 PDF View decision
  • Owen Kirkwood Clunie
    GLC attorney 2014-09-22 found breached

    Appeal Part Allowed | Court of Appeal decision delivered September 22, 2014. | Struck off - Disciplinary Committee Complaint 187 of 2012 decision delivered September 28, 2013 | Struck off again - Disciplinary Committee …

    Appeal Part Allowed 1 PDF View decision
  • Jacqueline M Durcan
    LSI solicitor Durcan’s Solicitors, No 1 Hazel Grove, Spencer Park, Castlebar, Co Mayo 2014-07-28 found breached

    In the matter of Jacqueline M Durcan, solicitor, formerly practising as Durcan’s Solicitors, No 1 Hazel Grove, Spencer Park, Castlebar, Co Mayo, and in the matter of the Solicitors Acts 1954-2008 [7083/DT14/12 and 2014 …

    strike_off View decision
  • Declan McEvoy
    LSI solicitor William Early Solicitors, 1 Haymarket, Carlow, and JM McEvoy & Co, Solicitors, The Avenue, Gorey, Co Wexford 2014-07-14 found breached

    In the matter of Declan McEvoy, solicitor, formerly practising as principal of William Early Solicitors, 1 Haymarket, Carlow, and JM McEvoy & Co, Solicitors, The Avenue, Gorey, Co Wexford, and in the matter of the Solic…

    strike_off 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.