EPR VidLec2 - Lawyer Responsibilities PDF

00:00 Hi, I\'m Eugene Torre Singam. Today what we\'re going to do is we\'re going to focus on a lawyer\'s responsibility to his client. That is, his responsibility to be honest, competent, diligent, as well as to maintain confidentiality with the client. These are important rules that govern the na...

00:00 Hi, I\'m Eugene Torre Singam. Today what we\'re going to do is we\'re going to focus on a lawyer\'s responsibility to his client. That is, his responsibility to be honest, competent, diligent, as well as to maintain confidentiality with the client. These are important rules that govern the nature of your interaction with clients. 00:28 and how you handle information, documents and facts which they pass to you. These duties are governed by the Legal Profession, Professional Conduct Rules 2015. In particular, we will focus on Rule 5 and 6, which we will be going through in turn. 00:51 Let\'s begin with a short introduction by Baroness Hale. The link is on the screen. You can watch it on your own time. After watching the video, you would have probably noticed, as well as having considered illegal professional rules, you would know that there are principles which guide the interpretation of each rule. There are three principles set out in Rule 5.1. 01:20 These are the relationship between a practitioner and his or her client, which imports a duty to be honest in all your dealings with the client. Second, a practitioner must have the knowledge, skill and experience to provide competent advice and representation to the client. The practitioner has a duty to be diligent. 01:49 First, the advice and information given to the client. Second, the manner in which you act for and represent the client. 02:00 Rule 5.2 lists the many specific duties of the practitioner, such as keeping the client informed of all information which may reasonably affect the interests of the client, keeping the client reasonably informed of the progress of his matter or claim. We will be going through some case studies for some of the specific duties which a lawyer owes his client. 02:28 We\'re going to deal with two cases first. In both these two cases, lawyers were dishonest with regard to their clients, as well as to their clients\' money, and they were, accordingly, struck off the roads. The first case, the case of Law Society of Singapore and Ng Kok Ho Dixon, the citation is on the screen. 02:55 A lawyer was entrusted with US\$100,000 to transmit as payment to another party on a contingent condition happening. When that condition failed to materialise, that is, there was no need to pay the monies over to a third party anymore, the client requested a refund. The lawyer, however, failed to refund the US\$100,000 to the client. 03:23 A disciplinary tribunal found that not only did he refuse to return this \$100,000 US dollars, but he had falsified documents intending to lead the Council of Law Society and his own accountant to believe that he in fact channeled monies according to his client\'s instructions, which was an obvious lie. He further said that he had rendered a bill for professional services for that amount. All these contradictory\... 03:53 confusing, rather with the intent to confuse, and clearly false statements which were made led to the Law Society to come to the conclusion the lawyer had been guilty of multiple false statements to the Law Society resulting in counts of grossly improper conduct, 04:22 The High Court, in commenting about this lawyer\'s conduct, said it was well established rule that if an advocate and solicitor is shown to be dishonest, he would invariably be struck off the roles. He went to say that a lawyer may be struck off where his honesty is not always shown, if he is shown to have fallen below the standards required, standards of integrity, probity and trustworthiness, citing the English Court of Peel. 04:51 decision of Bolton and Law Society. The court further emphasised that even if it were not court documents that were falsified, bills were important records relating to the client\'s account and I quote, It was beyond dispute that the bills produced by the advocates and solicitors are important documents and it is vital to the proper maintenance of accounting records that they mean what they say. 05:22 Moving on to Ng Chee Seng\'s case. In that case, the respondent acted on a premeditated scheme for personal profit. The scheme involved him causing two nominees to buy properties and then mortgage them to his clients, the mortgages. He then earned commissions on loans extended to outside third parties with monies from the mortgage funds. 05:50 He deliberately concealed this from the client. He repeatedly ignored and delayed responding to inquiries as to why the mortgages were not registered and hid the fact that he had not even attempted to these clients to have the purchase of the properties completed. The High Court found him to be guilty of grossly improper conduct. There was dishonorable to the respondent. 06:19 as a man and to his profession. And further stated that grossly improper conduct was not confined to misconduct in the solicitor\'s professional capacity, but it also extends to misconduct in his personal capacity as well. The court relied on his whole cause of conduct and character issues to strike him off as he was personally and professionally unreliable, untrustworthy and dishonest. 06:49 It is also to be noted that although the lawyer in question was a young, fresh lawyer having been admitted to the bar for only a year at the time of the wrongdoing and misconduct, the court did not give any weight to this as a mitigating factor as it involved pure dishonest acts. These two cases illustrate the importance of being honest and honourable in relation to your dealings and interactions with client. 07:18 whether in the cause of actually representing the client or dealing with them in a non-professional capacity as well. And it is not a mitigating factor at all to say that you are a young lawyer and you didn\'t know any better. I mean, how can you say that just because you\'re a young lawyer, you\'re entitled to be dishonest? One must also note the severity of the punishment that the courts mete out to get an understanding of 07:47 what weight the court places on unreliable, untrustworthy and dishonest conduct. Clearly, one would not be fit at all to practice as a lawyer. 07:59 Lawyers usually have access to and understanding of more information that is available to the client. There is a duty under Rule 52B to provide all information that is relevant and may reasonably affect the interests of the client. You need to give and put forward all the information which will affect the client\'s rights. You can\'t hide anything from the client. For example, in the case of 08:29 the lawyers failed to provide the plaintiffs with the requisite information, with enough information for them to make an informed decision about the purchase of a HDB shophouse. The property in question only had 17 years remaining of a 30-year lease. The clients had proceeded on the misperception held by the buyer that the property had 62 years of its lease remaining. 09:00 The nature of the tenancy offered by the vendor was not explained by the lawyer to the client, even though they had full knowledge of this. It was to be noted that the plaintiff buyer was commercially experienced in buying such shophouses, and in fact had dealings with six other shophouses at the time of this incident, all of which were ongoing transactions handled by the same lawyers. While the court accepted, 09:29 that it was not necessary for a solicitor to explain matters of a commercial or economic nature to the client, and that the client\'s experience is irrelevant factor, this consideration cannot be taken too far. It would be the basic duty to advise the client legally what kind of a transaction he\'s entering into and what would be the result of the transaction, what he would get from the transaction. And important to point out to him. 09:58 that he\'s only getting really 17 out of a remaining 30-year lease and not 62 years. The court restated that the solicitor assumes responsibility to the client by the nature of his or her professional expertise and it is not a defence to say that the lawyer did not breach his duty because the client is an experienced businessman or experienced purchaser of property. The correct approach which the court pointed out 10:27 was to ask whether the lawyers owed the clients a duty to take reasonable care in and handling the convincing transaction, and if so, whether they had been a breach of this duty, because they failed to inform and advise the client about the tenure and tenancy problems which the plaintiff should have been made known of, especially when any other reasonable solicitor 10:56 in place of the solicitors who had misconducted themselves, would have given that information or advice. There is therefore clearly a duty of care on the solicitor to advise and explain the legal implications of actions and assumptions as to the knowledge of the client, which are not to be taken lightly meaning, you\'re not to assume that the client will know certain issues just because they have done similar transactions before you owe a fresh duty. 11:26 to inform them about what exactly they are getting themselves into by signing the agreements. 11:36 Solicitors are also required to be reasonably diligent in their work. We now look at the standard of reasonableness in this regard. We turn to the case of K. Jayakumar Naidu. The facts of this case are as follows. The brother of a temporarily handicapped person hired the lawyer to execute the power of attorney in order to enable the brother to act in the sale of a flat. 12:05 belonging to the handicapped Mr He. After the power attorney had been granted the flat was sold and a loan was granted to the brother who was given the power of attorney on the security of the sale proceeds of the flat. This came to the attention of other members of the handicapped Mr He\'s family who through another lawyer, warned the lawyer who got into trouble on this issue that 12:32 Mr He did not know about the sale of the flat or the loan, and that the brother who had obtained the power of attorney was known to have a gambling problem. The other lawyer, for all these lawyers who got themselves into trouble, there was a reasonable suspicion that the loan was likely to be for the brother\'s gambling-related debts. The lawyers were asked to retain the loan disbursements. 13:00 in the interim while steps were taken to protect the interests of the handicapped Mr Hay. The lawyers appeared unwilling to comply with the request to hold the money until the issue could be resolved and further did not even comply and served with the deed of revocation of the power of attorney along with a letter providing for the sales proceeds to be paid to another law firm for safekeeping. The brother 13:28 original power attorney exerted pressure on the lawyer, who arranged for Mr Hay to be evaluated by a slight catcher and exercise another letter of authority directing sales proceeds to be paid into a back account. The lawyer allowed the brother to handle all these proceedings and eventually the monies in account were misappropriated by the brother. The court suspended the respondent for three months, highlighting the solicitor\'s duties to advance 13:58 client\'s interests with diligence and competence vary with the nature of the matter involved and the attributes of the client. In this case, Mr Hay was clearly a vulnerable client and required comprehensive and comprehensible advice for even the simplest of matters. While of course a solicitor need not approach every aspect of a transaction with a suspicious mind, where he had 14:27 cause or notice to be suspicious of possible risks, he was not entitled to be passive. Furthermore, the responsibility of assisting clients\' true intentions should not be nodded or delegated. The lawyers\' conduct in this case was measured again against the standard of a reasonably competent solicitor. That is, would a reasonably competent solicitor continue to act in this manner, notwithstanding the fact that lawyers on the other side 14:57 relatives were telling him, please do not release the monies, keep it until we can show you that the brother who\'s conducting all this is a gambler and there\'s a high chance that the monies would be misappropriated. In failing to advise the vulnerable client when given ample chances to do so, he had gravely and repeatedly failed to properly discharge his professional responsibilities and fell far short of the standards expected of a competent solicitor. 15:27 It should therefore be clear that you must always be reasonably diligent when providing services to the client. Always bear in mind the consequences for the client when you act. Always focus on what is happening with the case. Are there suspicious circumstances? Do not make assumptions that everything is okay. Most importantly, do not be passive when there are clear suspicions in the case that your client is being cheated. 15:56 The following subrules overlap with each other and all relate to timelines with respect to the client. 16:07 We are talking now in relation to PCR rules 52E, F, G and H, which deal with timely communications with the client. The case that we\'re going to look at is the case of Law Society and Cheong Chin-Mae Celina. In this case, the respondent solicitor was engaged to handle a divorce proceeding. From the time of engagement to the time of termination of the services, the solicitor was completely incompetent. 16:36 Disorganised, she displayed a complete lack of care towards the client. What she did was she gave sweeping statements, statements which cannot be backed up by law or common sense, inappropriate advice, that the complainant would get whatever she wanted in the divorce when asked about the impact of the husband\'s intention to go overseas. The lawyer failed to explain the processes and potential obstacles. 17:05 in the conduct of the divorce. There was lengthy and completely unreasonable delay in the filing of divorce papers. She misled the client to go with her to another firm. She was consistently late in appearing to court, among other things. Apart from her slipshot attitude in this case, she made the problems even worse when she failed to inform the client that the husband 17:32 had made a proposal to mediate and try to settle the matter, and instead demanded that the husband file his defence. As a result of all these transgressions, she was suspended for six months. Rules 5.1e to h guard against tardiness and solicitous behaviour, which as you can see, can have heavy consequences for the client and eventually the lawyer. 17:59 The duty to keep contemporaneous records of all instructions received from and advised rendered to the client is found in Rule 52K. It is important to keep records of instructions received from and advised to Spanish clients. While there is no practical or legal requirement to maintain verbatim notes of discussions, for example, in the case of Henry Rosely, which we will be looking at, 18:28 It is nevertheless good practice to maintain such notes as solisters can handle large volumes of cases over the years, and many forget details with the passage of time. The court in Lee Henry\'s day stated at paragraph 33 that the solister will have to satisfy the court that his recollection of events is case-specific and not a convenient reconstruction of events. In the absence of attendance notes to corroborate his or her version of the sentence, 18:58 events, you will have one less shield in your arsenal should you ever be accused of negligence or otherwise. Apart from defending yourself against the client, note-taking is also important in helping you maintain a high standard of service for the client by knowing what you know and knowing what you don\'t know. We will now move into duties in relation to confidentiality. 19:27 The specific rule is found in Rule 6.1, which states the following principal guides to interpretation of this rule, a legal practitioner\'s duty to act in the best interest of the legal practitioner\'s client, includes a responsibility to maintain the confidentiality of any information which the legal practitioner acquires in the cause of a legal practitioner\'s work. 19:56 confidential information when required by law, or when he has to consult with another in confidence in relation to discharging his own legal or ethical obligation or to his provider of indemnity insurance. Or if the client brings a claim against the lawyer or makes a complaint about the lawyer\'s misconduct. 20:24 The law is entitled to use confidential information to defend the charge or claim brought by the client. 20:33 It is important to read the specific duties and exceptions carefully, as confidentiality is a very serious matter. 20:45 However, it is important to note that this duty is only attached if the information is of a confidential nature. An important case in this regard would be Law Society and Ravi Madhusami. In that case, the respondent had emailed the press attaching letters from the State Court Registry and Supreme Court Registry on the scheduling of dates for hearings involving matters of the respondent\'s clients. 21:13 The Honourable Chief Justice, Sir Srinath Menon, found that the mere act of disclosure is not sufficient by itself to constitute a breach of confidentiality. We must of course look at the nature of the information. Is the nature of the information confidential or not? Because the rules only apply to confidential information. In Ravi\'s case, it was held that the hearing dates were public information available from published hearing lists. 21:42 There was therefore no breach of confidentiality by Ravi revealing the letters from the State Court Registry and the Supreme Court Registry on the scheduling of hearing dates involving a client. That said, much thought should be given before sending any information in relation to a client to third parties. It is also important to mark communications as privileged and confidentiality. 22:10 This is illustrated in the case of HTSRL and Wee Shua Woon. In that case, shortly after the plaintiff commenced a suit against the defendant, the plaintiff\'s computers were hacked and its contents were released on the internet. These contents included emails that were privileged communications between HTSRL and their solicitor. Most importantly, these emails contained express provisios that they contained privilege. 22:41 and confidential information. The defendant accessed these emails and relied on them to strike out the bulk of the plaintiff\'s case. What the court held was that regardless of whether the contents of the email would prove fatal to the suit brought by the plaintiff, the obligation of confidentiality could still be imposed on the defendant precisely due to the express provisos when they marked the 23:09 in the contents of the email. 23:14 More details relating to requests for information and professional secrecy can be found on the paragraphs listed in the slide. Please read them carefully. 23:27 This is the end of the topic of responsibilities of honesty, competence, diligence and confidentiality to the client. Thank you. B24 EPR - II\. Relationship with the client - \(1) Formation of **[Retainer]** - Who is a \"client\": section 2(1) LPA; Law Society of Singapore v Uthayasurian Sidambaram \[2009\] 4 SLR(R) 674 at \[39\] to \[44\] - **[ Implied retainer:]** - Law Society of Singapore v Ahmad Khalis bin Abdul Ghani \[2006\] 4 SLR(R) 308 at \[64\]-\[73\]; **[Factors considered for finding of implied retainer]** - Anwar Patrick Adrian v Ng Chong & Hue LLC \[2014\] 3 SLR 761 at \[49\]-\[61\]; - c.f. Law Society of Singapore v Lee Suet Fern \[2020\] SGHC 255 at \[57\]-\[69\] - Position when instructed by agent: Fong Maun Yee v Yoong Weng Ho Robert \[1997\] 1 SLR(R) 751 - PD 7.4.2 - Reservation of Rights in Warrant to Act or Letter of Engagement; - PD 7.1.2 - Limitation of Civil Liability; - s11 UCTA - - PD 7.4.3 - Warrant to Act, Letter of Engagement and Referrals from Third Parties \[PD 7.4.3 will be non-examinable for the purposes of Part B EPR 2024\]. - \(2) **[Honesty,]** competence and diligence (Rule 5 PCR) - Law Society of Singapore v. K Jayakumar Naidu \[2012\] 4 SLR 1232 at \[85\]- \[91\] **[- pressures of practice is not an excused]** - - - - - Law Society of Singapore v Ng Bock Hoh Dixon \[2011\] SGHC 242 at \[31\]-\[35\] - **[Consequence for dishonesty is striking off]** - Lie Hendri Rusli v Wong Tan and Molly Lim (a firm) \[2004\] 4 SLR(R) 594 at \[42\]-\[45\] - **[Soliciotr\'s duty depends on the scope of the retainer]** - - - - Law Society of Singapore v Chiong Chin May Selena \[2013\] SGHC 5 - **[High level of diligence regardless of quantum of fee charged]** - - Law Society of Singapore v Udeh Kumar s/o Sethuraju \[2017\] SGHC 141 at \[25\]-\[30\] and \[102\]-\[109\] **[Dishonesty = striking off]** - - Law Society of Singapore v Chia Choon Yang \[2018\] SGHC 174 at \[44\]-\[55\] - **[Dishonesty = Struck off;]** **[Factors considered for striking off]** - Law Society of Singapore v Jaya Anil Kumar \[2019\] SGHC 12 at \[4\]-\[7\] - **[inexperience is not an excuse]** - - Law Society of Singapore v Yong Wei Kuen Paul \[2020\] SGHC 66 at \[8\]-\[16\] **[Struck off despite not benefitting from deception]** - Loh Der Ming Andrew v Koh Tien Hua \[2022\] SGHC 84 at \[110\]-\[120\] - **[Past erraneous conduct will be considered aggravating factor]** - Law Society of Singapore v Mohammed Lutfi bin Hussin \[2022\] SGHC 182 at \[23\], \[33\]-\[34\] - **[The court will not accept that there is a spectrum of dishonesty]** - Law Society of Singapore v Ooi Oon Tat \[2022\] SGHC 185 at \[2\]-\[4\] - **[Breach of solicitor\'s duties resulted in client\'s claim being time-barred]** - Law Society of Singapore v Ezekiel Peter Latimer \[2024\] SGHC 90 at \[36\]-\[50\] - **[Solicitor cannot depend on others to verify as an excuse]** - \(3) **[Confidentiality]** (Rule 6 PCR) - Whether information is confidential in nature: Law Society of Singapore v Ravi S/O Madasamy \[2015\] 3 SLR 1187 at \[33\] **[- The information disclosed must be confidential, and if so, client\'s prior consent must be obtained.]** PD 9.1.1 - Request for Information - PD 9.1.3 - Professional Secrecy & Privilege - **[Privilege last forever, unless waived by client]** - \(4) **[Conflict]**, or potential conflict, between interests of **[2 or more clients]** (**[Rule 20 PCR]**) - Preliminary considerations for legal practitioner - Scenario 1: Before the lawyer takes on the matter (**[Rule 20(2), (3), (4) and (7)]**) - Rule 20 (3)(b) Rule 20 (4) and (6) - Scenario 2: When the lawyer is already acting for the relevant parties (**[Rule 20 (5) and (6)]**) **[Exception]** to **[Rule 20]** under **[Rule 20(7)]** - Question: Are the interests of the relevant parties adequately protected? - Multiple clients - Law Society of Singapore v Ezekiel Peter Latimer \[2019\] SGHC 92 - **[unflinching loyalty]** - **[Multiple clients]**: Lie Hendri Rusli v Wong Tan and Molly Lim (a firm) \[2004\] 4 SLR(R) 594 at \[36\] and \[48\]-\[50\]; - Law Society of Singapore v Uthayasurian Sidambaram \[2009\] 4 SLR(R) 674 at \[34\]-\[53\]; - - Mahidon Nichiar bte Mohd Ali and others v Dawood Sultan Kamaldin \[2015\] SGCA 36 at \[63\]-\[80\]; -that transaction will be regarded as suspect and will be liable to be **[set aside]** - Cases involving **[implied retainers]** and/or the duty to ensure that non-clients are not under impression that legal practitioner is protecting their interests: - Law Society of Singapore v Ahmad Khalis bin Abdul Ghani \[2006\] 4 SLR(R) 308 at \[74\] - **[Interest of one client should not be prioritised over other clients]** - Law Society of Singapore v Ganesan Krishnan \[2003\] 2 SLR(R) 251 - **[The test is that of acting for a single client applied to each of all clients]** - - PD 7.2.1 - Acting Against a Public Authority - PD 7.2.2 - Acting for Both Applicant Creditors and Provisional Liquidator - PD 7.2.3 - Acting for Both Complainant and Accused - PD 7.2.4 - Acting for Both Debenture Holder of a Company and Receiver Appointed by the Holder - **[Only can act for both if the receiver has received independent legal advise.]** - PD 7.2.5 - Conflict of Interest - Acting **[Against Former Client in Litigation Pertaining to Same Transaction]** - PD 7.2.6 - Conflict of Interest - Mortgagor/ Mortgagee - \(5) Conflict, or potential conflict, between interests of **[current client]** and **[former client]** (**[Rule 21 PCR]**) - Harsha Rajkumar Mirpuri (Mrs) nee Subita Shewakram Samtani v Shanti Shewakram Samtani Mrs Shanti Haresh Chugani \[2018\] SGHC 155 the **[Bolkiah principle (prospective former client)]** - Lim Oon Kuin v Rajah & Tann Singapore LLP \[2022\] SGCA 29 - **[There needs to be unqualified perception of fairness in the eyes of the public]** - \(6) Conflict, or potential conflict, between interests of client and **[interests of legal practitioner or law practice]**, in general (**[Rule 22 PCR]**) - **[Actual harm to client is not required for this provision to apply]** - Law Society of Singapore v Loh Yong Sen - Then Khek Khoon and another v Arjun Permanand Samtani and another \[2012\] 2 SLR 451 - **[Duty applies to the entire firm]** - Law Society of Singapore v Udeh Kumar s/o Sethuraju \[2013\] 3 SLR 875 - **[Cannot turn a wilful blind eye]** - Law Society of Singapore v Tan Phuay Khiang \[2007\] 3 SLR(R) 477 - **[Failure to make inquiries]** - Ho Kon Kim v Betsy Lim \[2001\] SGHC 75; \[2001\] SGCA 64 at \[63\] - **[Solicitor cannot have personal interest in the case]** - Law Society of Singapore v Singham Dennis Mahendran \[2001\] 1 SLR(R) 1 - **[fell in love with client and convinced her not to reconcil with husband]** - Law Society of Singapore v Govindan Balan Nair \[2020\] SGHC 174 **There does NOT need to be any harm actually caused before this provision is contravened** - - - Law Society of Singapore v Tan Chun Chuen Malcolm \[2020\] SGHC 166 - **[Cannot furthered his own interests under false pretenses]** - - GN 7.4.2 - Providing Welfare Assistance to Clients. - **[Reserve the right to withdraw]** - - \(7) Conflict of interest in family proceedings (Rule 15B PCR) \(8) Prohibited **[borrowing]** transactions (**[Rule 23 PCR]**) - Law Society of Singapore v Yap Bock Heng Christopher \[2014\] 4 SLR 877 - **[Cannot borrow money from client]** - Wee Soon Kim Anthony v Law Society of Singapore \[2007\] 1 SLR(R) 482 - **[cannot take loans from client even though no undue influence is found]** - Law Society of Singapore v Thirumurthy Ayernaar Pambayan \[2015\] SGDT 2 - **[It is irrelevant both as a matter of liability and as a mitigating factor that the Complainant suffered no loss as a result of the two prohibited borrowing transactions.]** Law Society of Singapore v Chia Chwee Imm Helen \[2022\] SGHC 214 - **[the Court will not give weight to the mental health issues of the errant solicitor in considering stirking off]** - \(9) **[Purchases]** from client (**[Rule 24 PCR]**) - \(10) **[Gifts]** from client (**[Rule 25 PCR]**) - Law Society of Singapore v Wan Hui Hong James \[2013\] 3 SLR 221 - **[must decline the gift in the absence of independent advice]** - Law Society of Singapore v Manjit Singh s/o Kirpal Singh and another \[2015\] 3 SLR 829 - **[Cannot accept under the pretext of \"safe keeping\"; Will be liable even if the monies returned]** - LSS v Govindan Balan Nair \[2020\] 5 SLR 988 - **[Full and frank disclosure + Independent advice + consent to act]** - LSS v Tan Chun Chuen Malcolm \[2020\] 5 SLR 946 - **[Cannot enter into business transactions with clients]** - Law Society of Singapore v Lee Suet Fern \[2020\] SGHC 255 - **[There cannot be any waiver of conflict of interest after the fact, where the client was not fully appraised of the facts]** - LSS v Ong Teck Ghee \[2014\] SGDT 7 - **[Where the client decline to receive independent legal advice despite being advised to do so, this cannot operate as an exception. Only a certificate from third party solicitor will suffice]** - \(11) Completion of retainer and withdrawal from representation (Rule 26 PCR) - Chew Kim Kee v. Kertar & Co \[2004\] SGHC 95 - A solicitor owes duties of honesty, competence and diligence to his client and [must complete] the work pursuant to the client's instructions until the termination of the retainer Alfons Tanumihardja v. Thio Su Mien \[2005\] 2 SLR(R) 445 **Closing of a client file does not, in itself, terminate the solicitor-client relationship** Law Society of Singapore v Chiong Chin May Selena \[2013\] SGHC 5 Solicitors are expected to uphold a certain level of diligence and competence even if a low fee is charged PD 7.3.1 - Copies of Documents - PD 7.3.4 - Transfer of Clients\' Monies on Dissolution - - - GN 7.3.1 - Guidelines for Handling of Clients' Files When a Solicitor Leaves a Law Practice to Practise in Another Law Practice