**Catchwords: OCCUPATIONAL DISCIPLINE - LEGAL PRACTITIONERS)** - misleading and deceptive conduct --misleading the court- conflict of interest - acting as agent for a lawyer of a party in a case management hearing and representing an opposing party in bail application - failure to be open and frank in dealings with the Law Society - professional misconduct - admissibility of evidence -assessment of evidence - rule in _Jones v Dunkel_ - [2010] ACAT 73 - ACAT 2010 case summary — Zoe

ACTACAT

Catchwords: OCCUPATIONAL DISCIPLINE - LEGAL PRACTITIONERS) - misleading and deceptive conduct --misleading the court- conflict of interest - acting as agent for a lawyer of a party in a case management hearing and representing an opposing party in bail application - failure to be open and frank in dealings with the Law Society - professional misconduct - admissibility of evidence -assessment of evidence - rule in _Jones v Dunkel_

[2010] ACAT 73

ACT Civil and Administrative Tribunal|2010-10-19

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Source facts

Court

ACT Civil and Administrative Tribunal

Decision date

2010-10-19

Source

Original judgment source is linked above.

Judgment (94 paragraphs)

[1]

The application was brought under the provisions of the Legal Profession

[2]

Act 2006 (the LP Act). The LP Act gives the Tribunal power to make orders for the discipline of legal practitioners where the Tribunal is satisfied that a practitioner is guilty of either unsatisfactory professional conduct or professional misconduct. Those terms are defined in sections 386 and 387 of the LP Act respectively. The definitions are inclusive definitions. They elucidate or add to the relevant common law rather than replace it. 2. Professional misconduct is defined in section 387 as including unsatisfactory professional conduct that involves a substantial or consistent failure to reach or to maintain a reasonable standard of competence and diligence. It also includes conduct that justifies a finding that the practitioner is not a fit and proper person to engage in legal practice. 3. The common law definition of professional misconduct is drawn from a test formulated in the English medical profession case of Allinson v. General Council of Medical Education and Registration [1894] 1 QB 750 at 763.5-7_._ In summary, the test provides that a professional engages in professional misconduct if his, or her, behaviour would reasonably be regarded as disgraceful or dishonourable by professional colleagues who are of good repute and competency. The test has been recognized as applying to Australian legal practitioners in a long line of authorities. 4. 'Disgraceful' or 'dishonourable' behaviour requires more than mere negligence, however, behaviour that is grossly negligent or reckless may constitute misconduct. 5. The statutory definition of unsatisfactory professional conduct set out in section 386 of the LP Act, includes conduct that falls short of the standard of competence and diligence that a member of the public is entitled to expect of a reasonably competent practitioner. It comprehends behaviour that is not so significant that it can be described as disgraceful, but is, nevertheless, of a standard less than the standard that a member of the public is entitled to expect from a professional person. 6. It is described in in this way:

[6]

The applicant was represented by Mr Beaumont of counsel and the respondent, by Mr Archer of counsel, at the hearing of the application.
The evidence received by the Tribunal and the basis on which it was admitted, is described in some detail below because of its significance in this case.
Ms Natasha Werner, the prosecutor who appeared on the bail application, gave oral evidence. Mr Darryl Perkins, the legal practitioner who engaged the respondent to act as his agent at the CMH on 23 July 2008 also gave oral evidence.
Neither V, nor G, gave evidence. They were subpoenaed by the applicant and attended the tribunal premises in accordance with the subpoena. Neither counsel called on them to give evidence and, as a result, they were released from the subpoena.
The respondent elected not to give evidence.
A range of material was tendered and marked as exhibits. The prefix "A" is used for material tendered for the applicant. The prefix "R" is used for the one document tendered for the respondent.
Exhibit A1 is an affidavit with annexures marked A to G, sworn on 25 March 2009 by Robert Reis, the Professional Standards Director of the applicant. The affidavit recites information relevant to the commencement of the application and annexes documents that form part of the business records of the applicant and on which the applicant relies.
Annexure A is a copy of the letter from the presiding Magistrate to the Executive Director of the Law Society dated 14 August 2008 (the complaint letter). Mr Archer objected to Annexure A on the basis that its content is hearsay.
Section 394 of the LP Act provides for the making of complaints to the Law Society. Sections 394(3) and (4) set out mandatory formal requirements for a complaint. It must be in writing. It must identify the complainant and if possible, the person about whom the complaint is made. It must describe the alleged conduct, the subject of the complaint. In this case, the complaint letter satisfies the formal requirements for a complaint.
Complaints form the basis of applications to the Tribunal for disciplinary action. The Tribunal admitted the complaint letter under section 60 of the Evidence Act 1995 (Cth) for the purpose of establishing that a complaint was made and the content of the complaint. It was not accepted as proof of the facts asserted in the letter.
Annexure A included an enclosure - an advertisement from a newspaper. The enclosure was not tendered and does not form part of the exhibit.
Annexure B is a letter from the Law Society to the respondent dated 21 August 2008 enclosing a copy of Annexure A and asking for a response. The penultimate paragraph refers to the advertisement enclosed with Annexure A. It was not tendered and does not form part of the exhibit. The balance of the letter was admitted.
Annexure C is a letter from the respondent to the applicant dated 5 September 2008 containing his initial response and asking for further time to respond.
Annexure D is a further letter from the respondent that forms part of his response to the applicant. It is also dated 5 September 2008. The opening sentence refers to "attached transcripts". There are no transcripts attached to the annexure. The letter refers to various appearances in the Magistrates Court and it can be inferred from the letter that the transcripts that were attached related to appearances by the respondent before various magistrates on 23 July, 28 July, 30 July and 20 August 2008.
Annexure E is a transcript of the proceedings before the Magistrate on 28 July 2008.
No objection was made to the admission of Annexures C, D or E.
Mr Archer initially objected to Annexures F and G in their entirety.
Annexure F is a letter to the Law Society from the Magistrate dated 23 September 2008. It was written after the Law Society sent the respondent's letter which was marked A1-D with its attached transcripts to the Magistrate and invited her further response. The objection to Annexure F was that it should be excluded because its contents are hearsay and that the Magistrate should be present to give evidence. The letter was admitted under section 60 of the Evidence Act 1995 (Cth) on the basis that it was relied on for the purpose of evidencing the content of the complaint under investigation.
Annexure G is the respondent's reply to the Magistrate's further letter. It is dated 18 October 2008. Again, it is apparent on the face of the letter that it had enclosures that were not included with the annexure. The enclosures are described in the letter as signed statements from G and V, both dated 27 August 2008. The basis of Mr Archer's objection to Annexure G was initially that if Annexure F was not admitted, Annexure G was irrelevant. Mr Beaumont submitted that any response made by the respondent to the Law Society during the course of its investigation is of central relevance to the application and, in particular, to ground 3 and that the entire annexure should be admitted on this basis regardless of the admissibility of Annexure F. Mr Archer modified his objection. There was no objection to part of the letter being received. The relevant part says:

[15]

Mr Archer submitted that the rule in Jones v Dunkel does not have the effect proposed by the applicant. He emphasised the need to focus on the evidence in the case and on the proposition that a failure to give evidence cannot be used as a cure for a weak case. He described the case of Meakes as demonstrating no more than a factually specific application of the Jones v Dunkel rule. He described the observations set out above as reflecting the reality that the Tribunal can only act on evidence. There was no question of the applicability of the rule in this case because, he submitted, the evidence available is not capable of satisfying the Tribunal to the requisite standard.
The Tribunal accepts that the rule in Jones v Dunkel can apply in disciplinary proceedings - that much follows from the authorities. It is trite to say that it should only be applied in appropriate cases and that the applicant must prove its case.
Mr Archer submitted that an adverse inference could reasonably be drawn in respect of the applicant's case, as a result of the failure of Mr Beaumont to call V or G to give evidence. He noted that the documents containing the respondent's response to the applicant, including the statements of V and G, were tendered by the applicant and formed part of the applicant's case. There was no objection to or qualification to their tender and no challenge to V or G to cast doubt on the content of their statements. He argued that it was reasonable to draw an inference that the failure of the applicant to call V or G occurred because the applicant anticipated that their evidence would be unfavourable to the applicant's case.
It is clear that documents relating to the respondent's response, including the statements of V and G, were tendered by the applicant for the purpose of establishing the fact of, and the content of, the response to the applicant and not for the purpose of proving the facts asserted in the response documents. The response is central to the allegations in ground 3. There would have been no evidence of the response, given the respondent's election not to give evidence, otherwise.
A discussion between counsel during the hearing made it clear that Mr Beaumont did not call V or G to give evidence, even though his instructing solicitor had subpoenaed them to attend the hearing, because Mr Beaumont believed that Mr Archer would call them and that he would then be able to cross examine them. It is not reasonable to draw an adverse inference that the evidence of V and G would have been unfavourable to the applicant, in these circumstances.

[17]

The best evidence of the representations made by the respondent to the Court is contained in the transcript of the proceedings (Ex A1 -E). The transcript is close to a true copy of the audio recording (Ex 9). There are some differences which Mr Beaumont described as immaterial but which, at least in one section, the Tribunal identifies as adding to an understanding of what occurred. The audio recording adds to the evidence because it assists to understand the timing of the proceedings and the pace at which events unfolded. The tone of voice of speakers and manner in which they speak may also assist to interpret the words spoken. The parties accepted that the two exhibits were an accurate record of the bail application.
The Magistrate came on to the bench at about 11.49.17am and immediately called on V's matter. It is apparent from the audio recording that V has been brought into the court room just before this.
V is charged and is asked by the Magistrate if she is applying for bail. She says that she is.
The Magistrate asks V, "You haven't got anyone representing you?" V answer is responsive and made without hesitation; "No, I didn't - yeah, sorry". Her voice can be described as sounding "thick" but she speaks clearly.
The Magistrate and prosecutor talk about the application for bail. The prosecutor indicates that the victim is "in court". She tells the Magistrate that G has spoken to her, that he is not in fear for his safety and that he has suggested conditions that could be imposed on bail. The Magistrate asks about the attitude of the informant. The prosecutor indicates that although the informant is not present, the prosecutor is opposing bail on the grounds of a risk of reoffending and a risk that the defendant won't appear. V's record is tendered and there is a discussion about a prior conviction of failing to appear. V interjects to ask when she failed to appear. Again, she speaks without hesitation. Her words are clear. It is also clear from the nature and timing of the interjection that she understands and is following the discussion. The prosecutor provides brief information about the assault.
At 11.51.56am there is a background sound that is likely to be a door opening or closing. Mr Archer submitted that we should be satisfied that the sound is associated with the respondent entering the court. Mr Beaumont did not disagree and we accept that that is an appropriate interpretation of the noise. The sound occurs at the moment that the Magistrate says "...but G has indicated that he's not concerned for his safety?"
An extract of the transcript from page 3, line 24 to page 5, line 29 is set out below. It commences at about the time that the sound of the door can be heard in the background.
The prosecutor and the Magistrate continue to speak after that sound and about twenty seconds elapses before the respondent speaks.
In the extract, the respondent's name is omitted and initials substituted for the names of V and G. The point at which the door can be heard in the background is indicated by the character +. The character * has been added to indicate the speakers are speaking at the same time. The character # is used to show words spoken as an aside - sotto voce.

[39]

There is a pause of about 6 seconds between V's words "But he's very manipulative, I know that" and the words "I thought you were Legal Aid".
The evidence before the Tribunal was that V had a number of previous convictions. It is reasonable to assume that she was familiar with criminal proceedings and was familiar with bail applications.
The transcript shows that V told the Magistrate that no one was representing her. Her response to the Magistrate's question was made without hesitation or qualification.
V is not heard to say anything indicating that she recognized or acknowledged the respondent when he entered the room or that she had seen the respondent and given instructions to him immediately before being brought to the court from the cells.
It is apparent from V's answers to the Magistrate and her interjections that she was following the course of the bail application and that she understood what was happening. She was not hesitant about interjecting, but did not say anything in support of the respondent's attempts to appear for her.
Mr Archer invited the Tribunal to listen to the audio recording carefully to form a view as to whether V was affected by alcohol or drugs during the bail application. Certainly, V's voice sounds "thick", but there is no slurring of words and no hesitation or delay in responding to or asking questions. It is apparent from the interjection she made to question the prosecutor about her prior conviction for failing to appear, that she is following the course of the proceedings and understands what is being said. She displays no confusion or disorientation. There is no objective evidence that V's participation in the bail application was affected by drug or alcohol use and no reason for the Tribunal to draw an inference that there was some impairment that explains her denial that she was represented or her failure to acknowledge or support the respondent's appearance.
Mr Archer invited the Tribunal to be satisfied that the exchange between V and the respondent starting with V thanking the respondent, is consistent with V having seen the respondent in the cells before court, asking him to appear for her and signing an application for legal aid. Mr Archer described the exchange as fitting "hand in glove" with V's subsequent statements. The Tribunal does not accept this submission. The exchange is consistent with V not knowing who the respondent was, and mistakenly assuming that he was a legal aid practitioner because he came into the court room apparently to represent her on a bail application. It is consistent with V assuming that G had manipulated a scenario in which the practitioner would not be able to appear for her. Nothing is said to indicate that there was any connection at that point between the respondent and V. The exchange is consistent with V's statement to the Court that she was not represented.
The transcript shows that the respondent did not assert, and made no attempt to assert, that he was appearing for, acted for, had instructions to act for, had spoken to or seen, V.
The respondent made the following statements to the court:
- (i) that he had just been instructed in regard to the matter;
- (ii) he was instructed outside the court by V's partner who was the victim of the assault;
- (iii) he was not instructed by the victim of an alleged assault representing the defendant (see his denial of the proposition put to him by the Magistrate);
- (iv) his only instruction was to speak to the defendant.
The respondent repeated that he was instructed by G three times when questioned by the Magistrate. The word "instructed" was used deliberately and consciously by the respondent. Mr Archer submitted that the Tribunal should accept that the use of the word "instructions" by the respondent was not intended and that what the respondent should have said was," I was asked by G to act for V..". The evidence before the Tribunal was that the respondent was a busy practitioner and that his practice predominantly involved criminal law work. It is reasonable to assume that he knew the significance of the use of the word "instructed" and its meaning and that he knew how to announce his appearance appropriately. It is reasonable to assume that he knew that the fact that G may have asked him to act for V was irrelevant to the court in circumstances in which he had allegedly already been instructed by V. The Tribunal cannot re-interpret what the transcript shows were the respondent's clear words in the way Mr Archer suggests. The observations of Tobias JA in Meakes can be applied here:

[45]

The respondent first responded to the applicant in relation to the matters dealt with in Ground 1 in a letter dated 5 September 2008 (Ex. A1-D). The applicant wrote to him on 21 August 2008 (Ex A1-B) asking him to provide a response to the Magistrate's concerns that were described as "relating to the following":
1. Informing the Court that you had instructions to act for (V) when you did not have such instructions.
2. Conflict of interest
Ex A1-D encloses and refers to the transcript of the bail application. The respondent draws attention to his statement that he had been instructed outside the court by G and that his only instruction was to speak to V. He does not mention that he had, in fact, spoken to V in the cells before court and obtained her instructions, even though that issue was clearly raised for his response.
The respondent wrote again to the applicant on 18 October 2008 (Ex. A1-G). In this letter he asserts for the first time that he was instructed by V in the cells before he appeared and that "at the time I appeared I had a signed legal aid application in my firms (sic) favour nominating me to act in the matter. I have received a grant of aid from the application of 28/07/08."
The letter enclosed the redacted statements dated 27 August 2008 (Ex A2 and A3). The statements pre-date the first response letter (Ex A1-D). The statements are referred to in greater detail below but, we note, it is reasonable to infer that they were prepared for the purpose of responding to this complaint. Both statements say that the respondent had seen V in the cells before court. In her statement, V said that she signed a legal aid form before she was called up to a court. The respondent's failure to refer to the statements in his first letter of 5 September 2008, or to make any reference at all to V's instructions until his second letter when this issue was clearly central to the complaint, calls for an explanation. It is a matter wholly within his knowledge.
The response letter contains no explanation for the respondent's failure to tell the Magistrate that he was instructed by V and for his repeated references to the instructions given to him by G when questioned by the Magistrate.
The respondent next refers to the instructions he held from V in a letter to the applicant dated 22 November 2008 (Ex A1-E). In this letter he repeats the assertion that he was acting for V and that he held a signed legal aid application when he appeared on the bail application. His letter enclosed full copies of the statements signed by V and G dated 27 August 2008. Again, the letter does not offer any explanation of the repeated statements made to the Magistrate by the respondent to the effect that he was instructed by G.
The respondent sent the applicant a copy of the legal aid application. Mr Archer acknowledged, and it is reasonable to accept, that V's signature appears on the form but that save for that signature, all the handwriting on the form, is the respondent's. The form has been completed in two places to show that the date that the matter was next in court is 28 July 2008. The time of the next court date was shown in the respondent's hand, as 12pm. The date underneath V's signature is 28/7/08.
The last page of the form has a certification that must be completed by the solicitor submitting the form. The solicitor is required to:

[53]

The redacted statement of V (Ex A3) asserts the following:
- V saw the respondent in the cells on 28 July 2008 and asked the respondent to act for her in her bail application and on the charges she was facing;
- At that time she signed a legal aid application the respondent put under the door.
Her full statement adds:
- V really did not understand what was going on - this assertion is not consistent with the transcript;
- She had requested through a number of people that the respondent be contacted to act for her - this does not sit comfortably with V's exchange with the respondent indicating that she thought he was "legal aid" and her failure to acknowledge the respondent or support his attempts to represent her on the bail application;
- G spoke to the respondent outside the courtroom and asked him to do the bail application for V - this is not a matter within V's knowledge;
- V was bailed "thanks to" the respondent - it is clear that the respondent had no involvement in the Magistrate's decision to grant bail and there is no basis for V's belief to the contrary
The statement does not explain why V told the Magistrate that she did not have anyone representing her. The Tribunal does not attach any weight to V's statement as a result of the inconsistencies it contains and its failure to explain why V denied that she had representation.
The Tribunal also notes inconsistencies between the redacted statement and the full statement which detract from the weight that can be given to it. The statements were presented as being the same document, however the date on the bottom of the redacted statement is shown as "27 august 2008" and the date on the full statement appears as "27 August 2008". V's signature and signature block is differently positioned on the two documents. V's signature appears to be different on the two documents although this is difficult to see clearly because the signature on the redacted statement is crossed through. There are two extra sentences at the end of the full statement. There is some doubt that they are the same document.

[54]

The Tribunal is comfortably satisfied that this ground is made out.
The Tribunal finds that the respondent was not instructed by V before the bail application to appear for her, or to act for her, on the bail application on 28 July 2008.
The only interpretation that can be placed on the words and actions of the respondent and of V during the bail application as evidenced by the transcript and the audio recording is that the respondent did not have instructions from V to act for her when he appeared before the Magistrate.
The words used by both the respondent and V should be taken to mean what they say. The respondent was experienced in these matters. His repeated insistence that he was "instructed" by G and his failure to make any reference to instructions from V when he was in court must be accepted at face value.
There is no evidence that V was confused or affected by drugs or alcohol when she denied that she had legal representation. There was no reason for her to lie about not having legal representation to the Magistrate. The Tribunal accepts that when she told the Magistrate that she had no legal representation, V meant what she said. There is no evidence to refute that proposition.
The respondent made no attempt to explain his words and actions during the bail application in any of the material provided to the applicant. He simply asserted that he did hold instructions. V's statement contains no explanation of her words. G's statement adds nothing relevant.
The legal aid application does not provide any evidence to counteract the words and actions of either the respondent or V during the course of the bail application.
The respondent could have given an explanation by giving sworn evidence before the Tribunal. He chose not to do so. The Tribunal draws an inference from his failure to give evidence, that the evidence would not have been favourable to him, but we stress that even in the absence of an adverse inference, the tribunal is satisfied that the ground is made out on the basis of the clear evidence set out in the transcript and audio recording.
In the absence of any explanation by the respondent, the Tribunal finds that the respondent deliberately or knowingly misled the court. Given the evidence available as to the respondent's experience, there is no basis, absent an explanation of the respondent's state of mind given by the respondent on oath, for the Tribunal to find that the respondent was negligent.
The Tribunal acknowledges that the court was not misled to any significant extent and that the court did not act on the respondent's misleading actions but, misleading a court is a serious matter that is properly regarded as disgraceful.[14]
The Tribunal is satisfied that the respondent's actions should therefore be characterized as professional misconduct.

[58]

23 July 2008. His assertion was not contested. 5. There is a general principle that lawyers owe a fiduciary duty to give undivided loyalty to their clients which cannot be fulfilled if the duty is owed to two or more parties whose interests are in opposition.[15] 6. Conflicts of interest may arise in a variety of circumstances. There is no blanket prohibition on acting for more than one person in a matter, however there is potential for conflict whenever one practitioner agrees to represent two people who are connected in some way[16]. 7. Mr Beaumont submitted that on the basis of this test, the respondent's appearance on the bail application involved a conflict of interest. The respondent owed a duty to both G whose instructions he said he had received, and V for whom he purported to act. 8. Mr Archer submitted that this was too broad an application of the principle. The Tribunal accepts this submission. The potential for conflict was significant. The Magistrate's description of the respondent's position as "bizarre", namely that he was acting for V on the instructions of G, was apt. It was not a position that a prudent practitioner would allow him or herself to be in. The Tribunal cannot be satisfied however that the potential conflict was actualized. This appears to be more a matter of luck rather than good management, or the result of prudent behaviour, on the respondent's part. 9. The respondent did not, in fact, act for V on the bail application. The Tribunal has found that he had no instructions from V to act on the bail application. The respondent did act for V on her instructions during the proceedings after the bail application; however, she did not become his client until that time. 10. A conflict of interest could have arisen if the practitioner had possession of confidential information as a result of acting for G at the CMH, that he would have been required to use, in order to fulfil the duty he later came to owe to V. He argued that the evidence does not support a conclusion that the practitioner had any confidential information in his possession as a result of acting for G. Mr Perkins gave oral evidence about the CMH on 23 July 2008 and his engagement of the respondent to represent G. His two affidavits were admitted and marked as Exhibits A7 and A8. 11. Mr Perkins' evidence was unchallenged and can be summarized as follows: * he was instructed by G to act for him in relation to an assault charge in which V was the complainant or victim; * The charge was listed for a CMH at 2.30pm on 23 July 2008; * the CMH is mostly an administrative process, the purpose of which is to confirm the plea entered, set a date for hearing, determine which witnesses will be called and how long the hearing will take. Evidence is not tendered or given at a CMH; * he asked the respondent to act as his agent on behalf of G, shortly before the CMH was due to start, maybe close to 2.30pm, when he realized that he had another matter listed in another court for the same time; * he had a brief discussion with the respondent for the purpose of telling him what to say at the CMH; * his recollection is that this was a straightforward matter; * he handed the respondent the brief of evidence, with a covering letter from the DPP on which he wrote brief instructions for the respondent. The brief of evidence and covering letter was tendered and marked Exhibit A10. Mr Perkins identified his handwritten instructions on the letter; * his instructions included the date of the hearing, and the names of the two police witnesses who would be required. He wrote the word "complainant" to indicate that the complainant was also required to give evidence. The name of the complainant, namely V, was not shown; * these were his only instructions to the respondent because it was the only information that was needed for the CMH; * he probably gave the respondent the statement of facts and his file as well as the brief of evidence. The charge sheet which showed V as the victim of the assault would have been at or very near the top of his file; * he cannot remember if G was present at court or if he introduced the respondent to G although he noted that a hearing date would not have been set by the court if G was not present; * he received a file note dated 23 July 2008 that appears to be from the respondent about the CMH appearance confirming that he appeared on the CMH , that G was present at the time, that the matter was set down for hearing and that the two police witnesses were required "as I was instructed to ask for." 12. The transcript of the CMH was marked as Exhibit R1. The transcript shows the respondent announcing his appearance and indicating that G was "before the court". 13. There is a discussion about police witnesses. The prosecutor indicates that the complainant will be a witness. The name of the complainant is not mentioned. The Magistrate asks the respondent if this is likely to be a summary hearing. The respondent replies that it "appears to be roughly a summary hearing." 14. Mr Archer submitted that this demonstrates that the respondent knew little about the matter because it was a meaningless response. The respondent's lack of knowledge is further illustrated by the file note (Exhibit A12) in which there is no reference to the complainant as a required witness. Mr Archer points to this as highlighting the respondent's absence of attention to the details of the matter. 15. The Tribunal accepts that the evidence supports a finding that the respondent knew little about the matter in respect of which he was appearing for G. There is no evidence that he had any information in his possession that gave rise to a duty owed to G, to keep the information confidential. There is no evidence that the respondent saw or obtained any specific information about G or V other than the information given to him by Mr Perkins or discussed before the court at the CMH. These were matters of public record. 16. The Tribunal is not satisfied that Ground 2 is made out.

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Judgment (94 paragraphs)

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Cases Cited (21)

THE COUNCIL OF THE ACT LAW SOCIETY & THE LEGAL PRACTITIONER (Stephen Stubbs) (Occupational Discipline) [2010] ACAT 73 (19 October 2010)