Practising certificate disclosures

Disclosure of spent convictions

Under the Spent Convictions Act 1988 (see section 22 and Part 3 Division 4), it is unlawful to refuse or revoke a qualification required for the practice of a profession because of a spent conviction.

However, applicants for admission to the legal profession, lawyers, and foreign lawyers, must disclose a spent conviction to the Board (section 12 of Schedule 3). That conviction may be taken into account when the Board considers whether the applicant is a fit and proper person.

Additionally, if a legal practitioner is handed a spent conviction of a serious offence as defined in section 51 of the Uniform Law), or an offence specified in rule 15 of the Uniform Law , they are required to disclose this to the Board.

Disclosure Guidelines

There are guidelines for the holders of an Australian practising certificate or an Australian registration certificate, or for people applying for the grant or renewal of those certificates The guidelines set out matters that relate to the requirement to disclose matters about eligibility and suitability that may be considered by the Board in relation to whether a person is a fit and proper person.

1. Purpose of the Guidelines

The purpose of these Guidelines is to:

  • Inform applicants and practitioners that the Board places a duty and onus on each applicant and practitioner to disclose any matter that could influence the Board’s decision whether the person is a Fit and Proper Person
  • Inform applicants and practitioners that failure to disclose relevant matters, if subsequently discovered, can have serious consequences for an applicant or practitioner if the Regulatory Approach determines high impact conduct1
  • Provide guidance to the Board’s Admissions and Registration Committee (ARC), Professional Affairs Committee (PAC), Professional Development Committee (PDC), Executive Director and Officers when considering if a person is a “fit and proper person”, and the management of process in that regard.

2. Context

The Legal Profession Uniform Law (WA) requires that an application for the grant or renewal of an Australian practising certificate must be made in the approved form.2 The approved form may require the applicant to disclose matters that may affect the applicant’s eligibility for the grant or renewal of an Australian practising certificate or bring into question whether the applicant is a Fit and Proper Person to hold a local practising certificate3 . In addition, section 116 of the Legal Profession Uniform Law Application Act 2022 (Application Act) requires an applicant to provide documents and other information required by the approved form.

LPB Form 1 Application for a local practising certificate is the form approved by the Board for the grant or renewal of an Australian practising certificate. LPB Form 1 sets out the matters that should be disclosed to the Board to enable it to give consideration to and investigate the applicant’s suitability to hold a local practising certificate.

Those matters include matters relevant to an applicant’s or practitioner’s suitability to hold a practising certificate (Fit and Proper Person). They include general suitability4 , as well as automatic show cause events5 and designated show cause events6. In addition, an Australian practising certificate is subject to a statutory condition that the holder notify the Board within 7 days of certain events7. The obligation of disclosure under each of these provisions is set out below. 

2.1 Suitability (Fit and Proper Person) 

The Board must not grant or renew an Australian local practising certificate unless it is satisfied that the applicant is a Fit and Proper Person8. In considering whether a person is a Fit and Proper Person.

1. The ARC, executive director and officers have been delegated powers and duties in relation to the grant of a local practising certificate if the applicant has never held an Australian practising certificate or the applicant has not held an Australian practising certificate within the preceding five years. 

2. The PAC, PDC, executive director and officers have been delegated powers and duties in relation to the: 

  1. the grant of a local practising certificate if the applicant has held an Australian practising certificate within the preceding five years
  2. the renewal of a local practising certificate
  3. when a holder of a local practising certificate discloses matter(s) to the Board, or matters come to the attention of the Board through other sources. 

The Law does not provide a definition of a Fit and Proper Person but does specify a number of matters the Board must have regard to when considering admitting an individual to the legal profession9 and may have regard to in considering if an applicant is or is not a Fit and Proper Person10. A significant matter that the Board may consider is whether a person is “currently of good fame and character”11. 

Rule 10 of the Legal Profession Uniform Admission Rules 2015, provides that, in determining if a person is or is not a Fit and Proper Person, the Board must have regard to: 

  1. any statutory declaration as to the person’s character
  2. any disclosure statement made by the person
  3. any police report provided
  4. any student conduct report provided
  5. any certificate of good standing provided
  6. whether the person is currently of good fame and character
  7. whether the person is or has been a bankrupt or subject to an arrangement under the Bankruptcy Act or has been an officer of a corporation that has been wound up in insolvency or under external administration
  8. whether the person has been found guilty of an offence including a spent offence in Australia or in a foreign country, and if so – 
    1. the nature of the offence
    2. how long ago the offence was committed
    3. the person’s age when the offence was committed 
  9. whether the person has been the subject of any disciplinary action, howsoever expressed, in any profession or occupation in Australia of in a foreign country
  10. whether the person has been the subject of disciplinary action, howsoever expressed, in any profession or occupation that involved a finding adverse to the person
  11. whether the person is currently unable satisfactorily to carry out the inherent requirements of practice as an Australian legal practitioner
  12. whether the person has a sufficient knowledge of written and spoken English to engage in legal practice in this jurisdiction. 

A matter mentioned in rule 10 is relevant to suitability even if it happened before commencement of the Law. 

In addition, the Board may have regard to any matter set out in rule 13 of the Legal Profession Uniform General Rules 2015 in considering whether or not a person is a Fit and Proper Person. Rule 13 provides — 

  1. whether the person is currently of good fame and character
  2. whether the person is or has been – 
    1. an insolvent under administration
    2. a director or principal of an incorporated legal practice while the legal practice is or was insolvent
    3. a director of a company while the company is or was insolvent  
  3. whether the person has been convicted or found guilty of an offence in Australia or a foreign country, and if so — 
    1. the nature of the offence
    2. how long ago the offence was committed
    3. the person’s age when the offence was committed. 
  4.  whether the person has engaged in legal practice in Australia – 
    1. when not permitted to do so under a law or previous law of a State or Territory
    2. if admitted, in contravention of a condition to which the admission was subject
    3. if holding an Australian practising certificate, in contravention of a condition to which the certificate was subject or while the certificate was suspended 
  5. whether the person has engaged in legal practice in a foreign country – 
    1. when not permitted to do so by or under a law of that country, or 
    2. if permitted to do so, in contravention of a condition to which the permission was subject. 
  6. whether the person – 
    1. (i) is currently subject to an unresolved complaint, investigation, charge or order under an Australian law relating to the legal profession or under a corresponding foreign law, or 
    2. (ii) has been the subject of disciplinary action, however expressed, under an Australian law relating to the legal profession, or under a corresponding foreign law, that involved a finding adverse to the person
  7. whether the person – 
    1. is the subject of current disciplinary action, however expressed, in another profession or occupation in Australia or a foreign country
    2. has been the subject of disciplinary action, however expressed, in another profession or occupation in Australia or a foreign country that involved a finding adverse to the applicant
  8. whether the person’s name has been removed from – 
    1. a roll of Australian lawyers, however described or expressed, in any jurisdiction
    2. a foreign roll or practitioners
  9. whether the person’s right to engage in legal practice has been suspended or cancelled in Australia or a foreign country 
  10. whether the person has contravened, in Australia or a foreign country, a law about trust money or trust accounts
  11. whether, under an Australian law relating to the legal profession or a law of the Commonwealth, a supervisor, manager or receiver, however described, is, or has been, appointed in relation to any legal practice engaged in by the person 
  12. whether the person is, or has been, subject to an order under an Australian law relating to the legal profession or a law of the Commonwealth, disqualifying the applicant from – 
    1. being employed by, or a partner of, an Australian legal practitioner 
    2. managing a corporation
  13. whether the person is currently unable to carry out satisfactorily the inherent requirements of practice as an Australian legal practitioner
  14. whether the person has provided incorrect or misleading information in relation to any application for an Australian practising certificate under an Australian law relating to the legal profession 
  15. whether the person has contravened a condition of a previous Australian practising certificate under an Australian law relating to the legal profession 
  16. whether the person has contravened an Australian law relating to the legal profession 
  17. whether the person has contravened – 
    1. an order of a court or tribunal made in any proceedings 
    2. (without limitation) an order of a designated local regulatory authority or other person or body under legislation of any jurisdiction so far as the legislation relates to the control or discipline of any Australian lawyers or to the practice of the law
  18. whether the person has failed at any time to pay a required contribution or levy to the fidelity fund of a jurisdiction 
  19. whether the person has failed to comply with a requirement under an Australian law relating to the legal profession in relation to professional indemnity insurance 
  20. whether the person has failed to pay any costs or expenses for which the applicant was liable under an Australian law relating to the legal profession
  21. any other matter that is related to a matter referred to in other provisions of rule 13. 

In relation to holding an Australian practising certificate a person may be considered a Fit and Proper Person even though the person is within any of the categories of the matters referred to in Rule 13 if the Board is satisfied that the circumstances warrant the determination12. In addition to the statutory conditions imposed on an Australian practising certificate under the Law, the Board may impose conditions13  when granting or renewing an Australian practising certificate or during its currency, but any imposed condition must be in accordance with the Uniform General Rules and be reasonable and relevant. 

If the Board — 

  1. refuses to grant or renew an Australian practising certificate
  2. imposes a condition on the certificate and the applicant does not agree to the condition, 

the Board will, as soon as practicable, give the applicant an information notice. 

2.2 Show cause events

Pursuant to section 85 of the Law “show cause events” are of 2 kinds: 

  1. automatic show cause events 
  2. designated show cause events. 
2.2.1 Automatic Show Cause Events 

An automatic show cause event14 is any of the following in relation to a person who is an applicant for or the holder of a certificate — 

  1. a bankruptcy-related event 
  2. conviction of a serious offence or a tax offence, whether or not – 
    1. the offence was committed while the holder was engaging in legal practice as an Australian legal practitioner or was practising foreign law as an Australianregistered foreign lawyer
    2. other persons are prohibited from disclosing the identity of the offender 
  3. an event of a kind specified in the Uniform Rules15. 

A “serious offence” includes an indictable offence in Australia or a foreign country; and a “tax offence” is an offence committed in or outside Australia under the Taxation Administration Act 1953 (Cth). 

If an automatic show cause event has occurred at any time in relation to an applicant for the grant or renewal of an Australian practising certificate, the applicant must provide a statement to the Board (within the LPB Form 1) — 

  1. about the show cause event
  2. explaining why, despite the show cause event, the applicant considers himself or herself to be a fit and proper person to hold a certificate. 

The applicant need not provide a statement if the applicant has previously provided the Board with a statement of that kind, as a previous applicant in Western Australia for the grant or renewal of a certificate or as the holder of a certificate16. 

In relation to the holder of an Australian practising certificate, if an automatic show cause event occurs, the holder must give the Board – 

  1. a written notice stating that the show cause event occurred
  2. a written statement explaining why, despite the show cause event, the holder considers himself or herself to be a fit and proper person to hold a certificate. 

The written notice must be given to the Board within 7 days after the show cause event occurred and the statement must be given to the Board within 28 after the show cause even occurred. A longer period to provide the statement can be allowed by the Board if the holder makes application within the 28 day period. 

Under section 89 of the Law, when an applicant or holder of an Australian practising certificate provides the required statement to the Board, the Board must determine whether the person concerned is a fit and proper person to hold an Australian practising certificate. 

The Board may vary, suspend or cancel, or may refuse to renew, a certificate if the applicant or holder – 

  1. fails to provide a statement as required by the Law17
  2. has provided a statement but the Board does not consider that the applicant or holder has shown in the statement that, despite the show cause event, he or she is a fit and proper to hold a certificate (or can be considered such a fit and proper person if the Board is satisfied that doing so is warranted in the circumstances)
  3. has failed without reasonable excuse to comply with a requirement18 made in connection with an investigation of the show cause event concerned or has committed an offence under Chapter 7 of the Law in connection with any such investigation. 

If the Board determines that the applicant or holder is a Fit and Proper Person (or can be considered a Fit and Proper Person if the Board is satisfied that doing so is warranted in the circumstances) the Board – 

  1. must take no further action in relation to the show cause event
  2. may impose a discretionary condition that it considers appropriate in the circumstances. 

In determining automatic show cause event matters, the Board19 – 

  1. may, but need not, conduct an investigation into the matter
  2. is not limited to making its determination, or conducting any such investigation, on the basis of just the automatic show cause event concerned
  3. may have regard to the facts and circumstances that surround, arise in connection with, relate to or give rise to the automatic show cause event concerned.
2.2.2 Designated show cause events 

A designated show cause event20 is the service of a notice on a holder of a certificate – 

  1. alleging – 
    1. in the case of a holder of an Australian practising certificate – that the holder has engaged in legal practice outside the terms of a condition restricting his or her practising entitlements
    2. in the case of a holder of an Australian registrations certificate – that the holder has provided legal services not permitted by or under the Law
    3. in the case of a holder of an Australian practising certificate who is required to have professional indemnity insurance – that the holder does not have, or no longer has, professional indemnity insurance that complies with the Law in relation to the certificate
    4. a matter of a kind specified in the Uniform General Rules
  2. requiring the holder to provide a statement showing cause why the Board should not take action, specified in the notice, to vary, suspend or cancel the certificate. 

When served with a designated show cause event notice, the holder of the certificate must give the Board a written statement explaining why, despite the show cause event, the holder considers himself or herself to be a fit and proper person to hold an Australian practising certificate. The holder must give the statement to the Board within 28 days after service of the notice or a longer period allowed by the Board on application made by the holder within that 28 days. 

If the holder provides a statement, the Board must determine whether the person concerned is a Fit and Proper Person21. The Board may vary, suspend or cancel, or may refuse to renew, a certificate if the applicant or holder – 

  1.  fails to provide a statement as required by the Law22
  2. has provided a statement but the Board does not consider that the applicant or holder has shown in the statement that, despite the show cause event, he or she is a fit and proper to hold a certificate (or can be considered such a fit and proper person if the Board is satisfied that doing so is warranted in the circumstances)
  3. has failed without reasonable excuse to comply with a requirement23 made in connection with an investigation of the show cause event concerned or has committed an offence under Chapter 7 of the Law in connection with any such investigation.

If the Board determines that the applicant or holder is a Fit and Proper Person (or can be considered a Fit and Proper Person if the Board is satisfied that doing so is warranted in the circumstances) the Board – 

  1. must take no further action in relation to the show cause event
  2. may impose a discretionary condition that it considers appropriate in the circumstances. 

In determining designated show cause event matters, the Board24 – 

  1. may, but need not, conduct an investigation into the matter
  2. is not limited to making its determination, or conducting any such investigation, on the basis of just the automatic show cause event concerned
  3. may have regard to the facts and circumstances that surround, arise in connection with, relate to or give rise to the automatic show cause event concerned. 

If the Board refuses to grant or renew or cancels a certificate as a result of a determination that a person is not Fit and Proper Person, the Board may also decide that the person is not entitled to apply for a certificate for a specified period not exceeding 5 years25. The Board must give the person concerned a written notice of the Board’s decision.

 2.3 Notification of offence 

Section 51 of the Law makes it a statutory condition of an Australian practising certificate that its holder must, within 7 days, provide the Board with written notice if – 

  1. the holder has been charged with or convicted of a serious offence, a tax offence or an offence specified in the Uniform Rules26
  2. a bankruptcy-related event has occurred in relation to the holder
  3. the holder has become the subject of disciplinary proceedings as a lawyer in a foreign country. 

“An offence” is not defined in the Law, however a “conviction” is defined as a finding of guilt, or the acceptance of a guilty plea by the court, whether or not a conviction is recorded.27

There is no requirement for the practitioner to explain to the Board why the practitioner remains a Fit and Proper Person. However, a conviction does become a matter which the Board should take into account when considering whether or not a person is a Fit and Proper Person, and in that regard it may be relevant for the practitioner to provide the Board with a statement and an explanation of the events from which the charge or conviction arose.

All matters set out above go to whether a person is a Fit and Proper Person to engage in legal practice. 

3. Status of the guidelines 

These guidelines do not, and cannot, diminish or supplant a person’s duty to disclose any matter which may bear on they are a Fit and Proper Person. They only provide information about how the Courts and the Board have previously approached the requirement for disclosure. They also give examples of matters that a person might otherwise overlook when deciding what to disclose. 

It is important to note that any matter bearing on a person’s fitness should be disclosed, whether or not that matter is mentioned in these Guidelines. It is thus prudent for a local legal practitioner to err on the side of disclosing information which may turn out to be relevant in the eyes of the Board or the Court. 

4. Relevant principles 

The Board applies the following principles when determining whether a person is a Fit and Proper Person. 

  1. The onus is on a person to establish fitness.
  2. The statutory test is cast in the present tense – whether a person “is currently of good fame and character” and, "is a fit and proper person". Past conduct, though relevant, is not decisive.
  3. The candour demonstrated in any disclosure by a person is highly relevant when determining present fitness.
  4. A person’s present understanding and estimation of the person’s past conduct is relevant.
  5. If a person makes a full disclosure of a condition relevant to the person’s capacity (see Section 8 below) and demonstrates that the condition is appropriately managed, it is highly unlikely that the disclosure will lead to an adverse assessment of whether the person is a Fit and Proper Person. 

5. The duty of disclosure 

A person is required to disclose any matter which might be relevant to the Board in considering whether the person is currently of good fame and character and is a Fit and Proper Person. This will include any of the matters set out in sections 51, 87 and 91 of the Law that apply to the person and any matters that arise from the occurrence of events described at rule 10 of the Uniform Admission Rules and rule 13 of the Uniform General Rules. 

Further, any other matter that might be relevant to a decision by the Board or the Court about whether the person is a Fit and Proper Person must also be disclosed. Recent cases demonstrate that the Courts believe there is an increasing expectation that any matter relevant to the assessment of a person’s honesty will be disclosed. 

Unfortunately it is not possible to provide an exhaustive list of all matters which can turn out to be relevant to assessing whether a person is currently a Fit and Proper Person or of good fame and character, and which therefore need to be disclosed. 

Stated in general terms, however, the duty of disclosure extends to any matter which reflects negatively on the person’s honesty, candour, respect for the law or ability to meet professional standards. A person should provide a full account of any matter in the person’s disclosure, including a description of the person’s conduct. The description should not be limited merely to listing criminal charges or other consequences of the conduct. As already noted, there is an increasing expectation that any matter relevant to assessing a person’s honesty will be disclosed. 

A person should also avoid editing, or selecting only those matters which the person believes should be relevant to the question. Rather, a person should disclose every matter that might fairly assist the Board or a Court in deciding whether the person is a Fit and Proper Person. 

Revealing more than might strictly be necessary counts in favour of an applicant - especially where the disclosure still carries embarrassment or discomfort. Revealing less than may be necessary distorts the proper assessment of the applicant and may itself show an inappropriate desire to distort by selecting and screening relevant facts. 28

 6. Matters that should be disclosed 

The following are examples of matters that should be disclosed. 

  1. Criminal conduct 
    An obligation to disclose a criminal charge, as distinct from a criminal conviction, may arise, even if charges were subsequently withdrawn or the person was acquitted. The fact that a person’s character has been brought into question may be sufficient to give rise to a need to disclose in the eyes of the Board or a Court. It is usually inadequate for a person disclosing criminal conduct merely to list the relevant charges and convictions. A person needs to explain the circumstances giving rise to the charge or conviction. It is prudent for a person to disclose an offence, even if spent convictions legislation applies to that offence. 
  2. Intervention orders and apprehended violence orders.
  3. Infringement Offences 
    Offences resulting in a court-ordered fine or other sanction or else an administrative penalty, such as traffic or public transport offences, should be disclosed in circumstances where the frequency or number of fines, or the failure to pay fines, or the particular circumstances of an offence, should give rise to concern in the eyes of the Board or a Court about the person’s respect for the law. 
  4. Traffic Offences 
    See item (c) above.
  5. Academic Misconduct 
    Academic misconduct may need to be disclosed. It will generally be prudent to disclose this conduct whether or not a formal finding was made or a record of the incident retained by the relevant organisation. Academic misconduct includes, but is not limited to, plagiarism, impermissible collusion, cheating and any other inappropriate conduct, whereby the person has sought to obtain an academic advantage either for the person or for some other person.
  6. General Misconduct 
    A person may need to disclose misconduct which occurred in a workplace, educational institution, volunteer position, club, association or in other circumstances. Again it will generally be prudent to disclose this conduct, whether or not a formal finding was made or a record retained by any relevant organisation. General misconduct may include, but is not limited to, offensive behaviour, workplace or online bullying, property damage, sexual harassment or racial vilification.29 
  7. Making a false statutory declaration.
  8. Failure to report social security overpayment or other social security offences. 
  9. Tax Offences. 

7. Certificates of character

Anyone who supplies a certificate or reference of character to support a person: 

  1. must be informed of any disclosure of the type mentioned above that is made by the person
  2. must attest to that knowledge in the referee's certificate of character. 

Because of the privacy implications of disclosures about a person’s capacity (see Section 8 below), a referee who supplies a certificate of character need not be aware of any disclosure about the person’s capacity. 

8. Disclosures about capacity 

The Board will also consider whether a person has the present capacity to carry out the tasks of a legal practitioner. At common law, the principle is as follows: 

To be a fit and proper person for admission to the legal profession an applicant must possess the capacity to make the judgments necessary to meet appropriate professional standards in legal practice or otherwise ‘discharge the important and grave responsibilities of being a barrister and solicitor’ 30. 

A person’s capacity to engage in legal practice is a matter the Board may have regard in considering whether an applicant is or is not a Fit and Proper Person. Rule 13(1)(m) of the Uniform General Rules states: “whether the applicant is currently unable to carry out satisfactorily the inherent requirements of practice as an Australian legal practitioner”. 

Furthermore, in deciding whether a person is a Fit and Proper Person, in addition to each of the matters prescribed, the Board may also take into account any other matters relating to the person it considers are appropriate31. 

At common law, a person who is otherwise qualified to practise is presumed to have capacity to engage in legal practice unless the contrary is established. The Board may be satisfied that the contrary is established if there is evidence that the person does not currently have the ability, whether physically or mentally, to carry out the responsibilities of an Australian legal practitioner in accordance with appropriate professional standards. This underlines the importance of disclosure by an applicant of any matters that may be relevant to that assessment. 

Matters which a person should disclose include any condition which might affect the person’s present ability to engage in legal practice – for example physical impairment, mental illness or addictions. 

The Board assesses each person’s capacity individually, in the light of the person’s particular disclosures and any other supporting information. Provided information will include any historical or current medical evidence submitted by the person. For this reason, if a person discloses a condition that the Board may consider relevant to the person’s present capacity to engage in legal practice, it will be prudent also to provide a report from an appropriately-qualified medical practitioner relevant to the condition disclosed. 

The confidentiality of any personal or medical evidence disclosed to the Board by or on behalf of a person will be maintained. 

A disclosure about capacity may be made in a separate statutory declaration. 

9. Authorisation 

These Guidelines are authorised by the Board by its delegates, the PAC, ARC, and PDC. 


1 Regulatory Approach Statement July 2022 
2 Legal Profession Uniform Law Application Act 2022 s 116(1)(a) 
3 Legal Profession Uniform Law (WA) s 45
4 Legal Profession Uniform General Rules 2015 r 13; Legal Profession Uniform Law Admission Rules 2015 r 10 
5 Legal Profession Uniform Law (WA) s 87 
6 Legal Profession Uniform Law (WA) s 91 
7 Legal Profession Uniform Law (WA) s 51 
8 Legal Profession Uniform Law (WA) s 45(2) 
9 Legal Profession Uniform Admission Rules 2015 r 
10 Legal Profession Uniform Law (WA) s 45(2); and Legal Profession Uniform General Rules 2015 r 13 
11 Legal Profession Uniform General Rule r 13(1)(a) 
12 Legal Profession Uniform Law s 45(4) 
13 Legal Profession Uniform Law (WA) s 53
14 Legal Profession Uniform Law (WA) s 86 
15 The Legal Profession Uniform Rules made under Part 9.2 of the Legal Profession Uniform Law (WA) 
16 Legal Profession Uniform Law (WA) s 87(3) 
17 Legal Profession Uniform Law (WA s 87 and s 88 
18 Legal Profession Uniform Law (WA) Chapter 7 
19 Legal Profession Uniform Law (WA) s 89(4) 
20 Legal Profession Uniform Law (WA) s 90 
21 Legal Profession Uniform Law (WA) s. 92(1) 
22 Legal Profession Uniform Law (WA) s. 91 
23 Legal Profession Uniform Law (WA) Chapter 7
24 Legal Profession Uniform Law (WA) s. 92(5) 
25 Legal Profession Uniform Law (WA) s 94 
26 The Legal Profession Uniform Rules made under Part 9.2 of the Legal Profession Uniform Law (WA) 
27 Legal Profession Uniform Law (WA) s 6
28 Frugtniet v Board of Examiners [2002] VSC 140, per Pagone J.
29 By way of illustration, in XY v Board of Examiners [2005] VSC 250, Habersberger J found that an applicant was under a duty to disclose that a volunteer position had been terminated as a result of making offensive remarks to a fellow worker and that she was also required to disclose property damage she had caused at a meditation retreat, notwithstanding that charges were not laid.
30 Frugtniet v Board of Examiners [2002] VSC 140 per Pagone J.
31 Legal Profession Uniform General Rules 2015 r 13(1)(u)