A charge of misleading the court need not expressly allege 'deliberateness' or 'dishonesty' if the particularised facts can only convey deliberate conduct. A literally true statement can found a charge of misleading the court where the statement is misleading in context. It is not an abuse of process for a disciplinary body to receive submissions on both liability and penalty simultaneously, provided the respondent has the opportunity to address penalty, though the better practice is to separate them.
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