A barrister's deliberate deception of the court in disciplinary proceedings by filing an untruthful affidavit is treated as no less serious than deceptions in the course of practice. Cumulative personal misconduct involving drug offences, false statutory declarations, deception of the court, and association with drug culture — even where the underlying convictions are relatively minor — can demonstrate character unsuitable for legal practice warranting disbarment rather than a lesser sanction.
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