Knowingly misleading the court on two occasions, without mitigating circumstances, is of itself sufficient to warrant removal from the Roll. Collective findings of discourteous, offensive and abusive conduct towards judicial officers, police and court staff can independently demonstrate a character inconsistent with the privileges of practice, warranting striking off even absent dishonesty. A practitioner's lack of insight into the impropriety of their conduct and absence of remorse significantly increases the risk of recurrence and weighs heavily in favour of removal.
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