The Full Bench of the Supreme Court of Western Australia ordered the removal of a legal practitioner's name from the roll of Australian lawyers pursuant to s 23(1)(b) of the Legal Profession Uniform Law (WA), where the practitioner had been convicted of 27 instances of dishonesty (gaining pecuniary benefit by fraud under s 409(1)(c) of the Criminal Code 1913 (WA)) committed while employed as a solicitor. The Court confirmed that even where removal is consented to by the practitioner and recommended by the Legal Practice Board, the Court must independently satisfy itself that removal is warranted. The Court reiterated that willingness to engage in dishonest behaviour is of central relevance to fitness to practise and that allowing the practitioner to remain on the roll would undermine public trust in the integrity of the legal profession and the administration of justice.
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