An applicant for admission to the legal profession who has engaged in inappropriate conduct in litigation must demonstrate not merely that they accept their conduct was wrong, but that they understand why it was wrong and what they would do differently. The ability to impose conditions on a practising certificate arises only after the threshold finding that the person is fit and proper, and cannot be used to qualify that threshold requirement. The duty of disclosure under r 17 of the Admission Rules extends to adverse judicial comments about the applicant's conduct in litigation, and disclosure of the existence of a proceeding is not sufficient without disclosing the substance of adverse findings.
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