Where a legal practitioner's unprofessional conduct is sustained, cumulative, and includes dishonesty, supervision or suspension will not be an appropriate penalty — only removal from the Roll will adequately protect the public and maintain confidence in the profession. A Tribunal's failure to refer such matters to the Supreme Court will result in a manifestly inadequate penalty. Failure to make restitution for dishonestly obtained monies seriously undermines claims of contrition and remorse.
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