Conduct involving misleading the court on multiple occasions, preparing false affidavits, and fabricating file documents is at the extreme end of unprofessional conduct and will ordinarily warrant striking off. However, where a practitioner has voluntarily ceased practice for an extended period and shows evidence of rehabilitation, the court may adjourn a striking off application to allow the practitioner to address evidentiary deficiencies, particularly the absence of independent workplace character references. Medical evidence of depression may be a relevant but not determinative factor; it will not wholly explain or excuse a sustained course of dishonest conduct.
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