Solicitors Disciplinary Tribunal refuses to lift practice restrictions on solicitor suspended in 2018, finding insufficient evidence of rehabilitation or work lost due to conditions
The Solicitors Disciplinary Tribunal (SDT) refused on 3 November 2026 to lift three remaining conditions on the practising certificate of solicitor Kulwant Singh Manak, ruling that he had produced insufficient evidence to show the restrictions were punitive in effect. Manak was suspended for two years in January 2018 following proceedings brought against him and other partners at Coventry firm Heer Manak, which closed in 2013 after failing to secure indemnity insurance. The original SDT findings included that Manak had acted recklessly and without integrity by allowing client accounts to operate in breach of rules, obtaining a loan from a client without requiring independent legal advice, and failing to supervise staff properly. Three conditions were removed by the High Court in summer 2018 when Manak's suspension appeal failed. The three remaining conditions prevent him from being an owner or manager of a law firm, acting as a compliance officer, or practising as a sole practitioner. Manak, who has worked since 2020 as a consultant solicitor at Coventry firm Maya and Co Solicitors, argued the conditions had caused him difficulties obtaining work. The SDT found that documents submitted, including a Land Registry correspondence, a will-related letter, and a record of his High Court appeal, did not establish that work had been lost specifically because of the restrictions. The tribunal also found his professional development evidence, comprising certificates from three courses completed in 2024, provided limited information about learning outcomes. His character reference was described as supportive but general and lacking specific rehabilitation evidence.
Why this matters
The decision illustrates the high evidentiary bar the SDT applies when solicitors seek to modify conditions imposed following serious regulatory findings. The tribunal's reasoning is instructive: merely demonstrating that conditions are inconvenient or that work opportunities have been declined is insufficient without documentary proof of a causal link between the restrictions and the lost work. The case also underscores that conditions relating to ownership, management, and compliance officer roles are treated as protective rather than punitive by default, placing the burden squarely on the applicant to demonstrate otherwise with specific, contemporaneous evidence.
On the Ground
This decision is relevant to regulatory and professional discipline practice groups, particularly those advising solicitors subject to SDT conditions or SRA enforcement action. It highlights the importance of building a detailed, contemporaneous evidential record of rehabilitation, including firm confirmation of employment status, client testimonials, and substantive course completion evidence, rather than relying on oral submissions and general character references. No law firms are named as advisers in the source. A trainee working on a professional discipline matter would assist with compiling witness statement bundles, preparing chronologies of the regulatory history, and reviewing documentary evidence for relevance and admissibility.
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“What standard of evidence must a solicitor meet to persuade the SDT to lift conditions on their practising certificate, and what does this decision tell us about the burden of proof?”
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