LEGAL PRACTICE BOARD -v- WOODHOUSE [2026] WASC 95 (25 March 2026)

1. On the basis of the Conviction (and the conduct underpinning the Conviction), the Board:

(a) contends that Mr Woodhouse is not of good fame and character such that he is not a fit and proper person to remain on the Supreme Court roll; and
>
> (b) recommends to this court that his name be removed from the Supreme Court roll.

11. With respect, the Board correctly submitted:[8]
    1. The Court is not bound to accept the recommendation of the Board but must independently exercise the power under s 23(1)(b) of the Uniform Law on the evidence before it.
    2. Even if Mr Woodhouse concedes the removal of his name from the Supreme Court roll (as he has done by way of a signed consent order in this case), the Court must still be satisfied that the removal of his name is an appropriate order to be made. (original emphasis; citations omitted)
12. On all of the material filed, the Court was comfortably of the view that:
    1. the Practitioner's willingness to engage in dishonest conduct on multiple occasions, over a prolonged period of time, was misconduct of a most serious kind; and
    2. the Practitioner's further attempts to deceive his employer once suspicions were raised about his illegitimate claims represented further instances of dishonesty on his part.
13. The Court was unanimously of the view, consistently with the principles which we will come to shortly, that the Practitioner's name should be removed from the roll of Australian lawyers maintained by this Court.
14. In our view, to allow his name to remain on the Supreme Court roll would undermine the public's trust and confidence in the honesty and integrity of legal practitioners, and, consequently, in the administration of justice.

1. The relevant principles applicable to an application such as this were recently set out by the Full Bench in Legal Services and Complaints Committee v Frost[9] (Frost) at [13] ‑ [17], [19], [22] and [24] (Lundberg, Lemonis, Gething JJ).[10] They do not need to be repeated in full here.
2. As stressed in the recitation of those principles:

Honesty, fairness and integrity are essential prerequisites to the right to practise law. The quality most likely to result in removal of a practitioner's name from the roll is conduct which undermines the trustworthiness of the practitioner or which suggests a lack of integrity, or that the practitioner cannot be trusted to deal fairly within the system in which he or she practises. The willingness to engage in dishonest behaviour is of central relevance to an assessment of a practitioner's fitness to practise.[11]

1. This Court is in no doubt that the removal of the Practitioner's name is fully justified when regard is had to the Conviction, the matters in the agreed facts, and the other material filed.
2. Further, the Court is satisfied that the removal of the Practitioner's name from the roll is necessary for both the protection of the public and the maintenance of the reputation and standards of the legal profession.
3. It is for those reasons that the Court made the orders it did unanimously on 20 March 2026, namely:
   1. pursuant to s 23(1)(b) of the Legal Profession Uniform Law, Clayton Steven Woodhouse's name be removed from the roll of Australian lawyers maintained by this honourable Court; and
   2. there be no order as to costs.

I certify that the preceding paragraph(s) comprise the reasons for decision of the Supreme Court of Western Australia.

[1] The Board is a 'designated local regulatory authority' for the purposes of the Legal Profession Uniform Law (WA) by virtue of s 20 of the Legal Profession Uniform Law Application Act 2022 (WA).

[2] The Legal Profession Uniform Law (as enacted by the Legal Profession Uniform Law Application Act 2014 (Victoria) Schedule 1) is applied and modified as a law of Western Australia by or under the Legal Profession Uniform Law Application Act 2022 (the WA Application Act). Provisions in Victorian Acts that amend the Legal Profession Uniform Law (the Law) also amend the Law as it applies in Western Australia where those amendments have effect and have commenced in Western Australia under sections 9 and 10 of the WA Application Act.

[3] By Originating Motion filed on 23 February 2026 (Application).

[4] Affidavit of Michaela McGurdy made on 19 December 2025 and filed on 23 February 2026.

[5] The Board's submissions filed on 23 February 2026 (Board's submissions).

[6] Victorian Legal Services Board v Gobbo [2020] VSC 692 [5] ‑ [6].

[8] Board's submissions [19] ‑ [20].

[9] Legal Services and Complaints Committee v Frost [2026] WASC 22.

[10] The principles summarised by the Full Bench in Frost at [22] and [24] were derived from Legal Profession Complaints Committee v Bower [2019] WASC 281 [38] (Quinlan CJ, Kenneth Martin & Smith JJ), Legal Profession Complaints Committee v Chang [2022] WASC 145 [54] (Quinlan CJ, Hill & Strk JJ) and Legal Practice Board v Elek‑Roser [2024] WASC 405 (McGrath, Hill & Lundberg JJ).