In the legal profession, professional misconduct primarily refers to an advocate's dishonourable or disgraceful behaviour. It can be characterised as behaviour that deviates from what an organization's head considers respectable or appropriate. With this essay, the author hopes to give a general overview of the subject as it relates to the problem of "Professional Misconduct" in the legal field.

The types and instances of professional conduct, the responsibilities of advocates, the code of conduct that is prescribed for advocates, and some significant rulings on the subject are all covered in this paper. This paper addresses the situations that qualify as professional misconduct, the Advocates Act of 1961, and the Act's code of conduct for solicitors. The Act of 1961's numerous obligations and limitations on advocates are also mentioned by the author. The study examines how important court rulings have shaped our knowledge of and progress towards enacting legislation pertaining to professional misconduct.

Introduction:
"Professional Ethics cannot be contained in a Bar Council rule nor in traditional cant in the books but in new canons of conscience which will command the members of the calling of justice to obey rules or morality and utility." - Justice Krishna Iyeri

Being an advocate is a noble and moral career choice. One could consider advocates to be among society's most privileged, responsible, and intelligent people. Because advocates have such a high status in the community, they could be looked up to as role models by others; therefore, their actions should always be controlled. The corporate and personal standards of behaviour that are expected of a professional are included in professional ethics.

As a result, to practise their profession, professionals must adhere to certain values or standards of ethics. In short, inappropriate behaviour is referred to as "professional misconduct." An advocate might do it to satisfy his own desires or to make ends meet.

Professional misconduct is defined as any action that puts the advocate in conflict with their profession or renders them unfit to practise. Put simply, any action that prevents an advocate from practicing their profession. It is evident that the legal profession is a noble, polite, and uncontaminated one rather than a business or trade.

The conduct of the members of the profession plays a vital role in determining the trustworthiness and stature of the profession.

Professional Misconduct includes the following situations:

• Betraying the trust of a client
• Practising fraud through certain means
• Deceiving the court
• Deceiving the opposing party or their counsel

The Supreme Court examined the following when discussing "Professional Misconduct" in State of Punjab v. Ram Singhi:

• Improper or inappropriate behaviour
• Behaviour that is unlawful according to law
• Immorality
• Carelessness in discharge of duty
• An act forbidden by law
• Or transgression

The Advocates Act of 1961's Chapter V addresses the Advocates' behaviour. The chapter goes on to detail the advocates' provision for punishment for any kind of misbehaviour. Section 35(1) of the Act states that the State Bar Council must refer an advocacy's actions to the disciplinary committee for resolution if they have reason to believe the advocate has engaged in misconduct of any kind.

Although the Bar Council and the Act do not specifically define professional misconduct, serious penalties have been established for any registered advocate who commits or fails to commit such an act.

Historical Background:
A key component of the system for regulating justice is the legal profession. The absence of as:
Regulated legal profession would make it impossible for the courts to successfully administer justice because they would be unable to properly connect facts, marshal evidence in favour of or against the parties in a lawsuit or present the strongest defences or rejoinders to the court. "An appropriately furnished and effective bar is a prerequisite for a well-functioning judicial administration system." The evolution of the legal profession in India is therefore something that should be carefully noted in the fitness of things.

The inception of the legal profession in India dates to Governor Aungier's establishment of the First British Court in Bombay in 1672. The Governor-in-Council, not the Court, was tasked with admitting or acknowledging solicitors. There were no attorneys in practice prior to the Mayor's Courts being established in Madras and Calcutta in 1726. A recognised legal profession did not exist prior to the Mayor's Court's founding. Lawyers were not trained in law, and some of the mayor's court officials were former British East India Company employees. A few key years contributed significantly to the establishment of Indian courts

Instances Of Misconduct By Advocates:

• Non-performance of Duty:
  The term "dereliction of duty" is another term for this circumstance. It can be defined as the circumstance in which an attorney either transfers the case brief to another attorney or deserts the client and neglects to fulfill his obligations. A transfer of this kind is thought to be unprofessional. But if the advocate acts in this manner after obtaining the client's consent, it is not improper.

  V.C Ranga Durai vs D. Gopalan

  The Apex Court made it clear that a lawyer assigned a case, and its brief has a duty to uphold the standards of professional ethics and, as a result, defend the client's interests. It would be considered professional misconduct if this weren't done.
   

• Negligence on behalf of the Professional:
  An advocate is supposed to use the appropriate abilities and expertise as they proceed with the case. Furthermore, it is anticipated of him to act with caution and diligence. But if the advocate was careless and fabricated information or withheld the truth, that would be considered professional misconduct.

  Mohd. Ismail versus Balarathnaiv

  The Supreme Court in this case stated that, despite several adjournments, it would constitute misconduct if a lawyer failed to provide the required paperwork to continue the case.
   

• Misappropriation:
  Misappropriation is a form of misconduct that occurs when an advocate receives money from his client for purposes connected to the case, but the advocate misappropriates the money for reasons unrelated to the case.

  In this case, an advocate was charged with embezzling the money he received from the client. The remaining sum was used for professional fees, and the sum was obtained in order to file a lawsuit. The advocate who placed the blame on the High Court stated that the suit papers were misplaced by the High Court registry. It was discovered, nevertheless, that the advocate had not refiled the suit for a considerable amount of time and that the registry had returned the suit papers to the attorney for the purpose of removing objections. An advocacy committee was placed under disciplinary committee. The committee punished the advocate for misconduct after finding that the advocate had embezzled client-paid funds.
   

• Contempt of Court and Inappropriate behavior before the Magistrate:
  A person who violates the justice system, the court's authority, or its dignity by acting in a manner that is disrespectful or disobedient towards the court or any of its officials is guilty of contempt of court. Respecting and upholding the dignity of the court is the obligation of an advocate. Any false accusations made against a judge or other court official are considered misconduct. There are two distinct forms of contempt: acting inappropriately towards judges in court or completely disobeying the court's orders.

  The leader of the Communist Party of India, M.V. Jayarajan, was sentenced to six months in prison in 2010 for contempt of court after he made remarks that were critical of the Kerala High Court's ruling to forbid public gatherings. Nevertheless, following an appeal to the Supreme Court, his sentence was shortened to four months.
   

• Giving Out False Information:
  It is misconduct for an advocate to knowingly provide a public servant with misleading information. The information may deal with an offense that has already been committed or it may deal with committing an offense and stopping others from doing so. The advocate will face consequences for professional misconduct if he is aware of, or has reasonable suspicion that, the information being provided is untrue.

Emperor v. K.C.B. A Pleader vii:
In this case, the advocates falsely claimed that the Municipal authorities had ordered that the boxes be restored to their rightful owners. As a result, Mr. Bazrang Marwari was found guilty and faced misconduct proceedings. The Municipal authorities had seized certain boxes of "ghee" after receiving information that the "ghee" was adulterated. The advocates ordered that the boxes be kept under the custody or supervision of Mr. Bazrang Marwari.

Advocates Act, 1961

The Advocates Act of 1961's Chapter V addresses the behaviour of the Advocates. Through several provisions, Section 35 of the Act addresses allegations of professional misconduct against Indian advocates and lawyers.

If an advocate is found guilty of professional misconduct, the State Bar Council's Disciplinary committee will be tasked with handling the case. The disciplinary committee will then need to schedule a time for the matter to be discussed. It must also send a show cause notice to the State's Advocate General and Advocate. Following hearing from both parties on the scheduled date, the committee may take the following actions.

• Reprimand or reprove the advocate for the charges;
• As it deems fit to the Committee, suspend, or charge the advocate for an appropriate period;
• Withdraw the advocate's name from the state roll;
• Either dismiss the complaint against the advocate if it feels that the issue is not too grave or
• Direct the filing of proceedings at the same place where the State Bar Council initiated the proceeding.

Misconducts come in countless forms. Therefore, it is imperative that the term "misconduct" be understood broadly, to the point where its definition falls under the umbrella of natural law, eliminating any room for regulation of the term's inherent meaning. The Bar Council of India is empowered by Section 49 of the Advocates Act to establish guidelines and regulations pertaining to professional misconduct.1) The Act states that no advocate may promote or solicit business because doing so would be against the Advocates' code of ethics. It is forbidden to advertise directly or indirectly. Additionally, he is not permitted to promote through interviews, circulars, or private correspondence.

It is forbidden for the advocate to use indirect advertisement in the following ways:

• The publication of election manifestos or circulars that include the name, address, and profession of advocates; this serves as a sort of call to action for members of the same profession who are currently employed by lower courts to recommend their clients to legal counsel.
• Sending out his agents or clerks to different districts in the state to speak with advocates practicing in the lower courts directly.
• Using tours of the province to solicit votes.
• The size of an advocate's nameplate or signboard shouldn't be excessive.

It should also not include any information about the advocate, such as whether he is or was president of the Bar Council or any other organisation of that kind, or whether or not he has ever served as an advocate general, a judge, or even just someone with a particular area of expertise.

Additionally, he is not allowed to demand payment for training, which makes it possible for an aspirant attorney to fulfil the prerequisites for State Bar Council enrolment.

1. He is not permitted to link his name or services to any unofficial activities or goals connected to the law or any legal agency.
2. In any case where a party has already hired an advocate, he is not permitted to enter appearance. He may do so after getting the involved advocate's approval. If the advocate's consent is not presented in court, they must provide a valid explanation for their inability to do so. He is only permitted to make an appearance later with the court's approval.

Code Of Conduct Prescribed For Advocates

viii: The Bar Council of India is authorised to create regulations governing the standards of professional behaviour by Section 49 of the Advocates Act of 1961. Consequently, there are

viii Professional misconduct of lawyers in India by author elbeepeter available on Professional misconduct of lawyers in India (legalservicesindia.com) visited on 1.12.2021. Several responsibilities set out for advocates, some of which are listed below. Nothing about advertising or soliciting work; doing so violates an advocate's code of ethics and is considered misconduct on their part. It is forbidden to advertise both directly and indirectly.

A representative of an advocacy group is not permitted to promote their services through newsletters, ads, touts, unwarranted personal correspondence, or interviews. Likewise, it is forbidden to use the following types of indirect advertising.

1. by publishing election manifestos or circulars written by a lawyer with his name, occupation, and contact information on them, making an appeal to the members of the profession working in the lower courts who can refer clients to attorneys working in the High Court.
    
2. requesting votes by travelling the province or dispatching his clerk or agents to the different districts; this will inevitably entail making direct contact with solicitors who are employed by lower courts. Furthermore, an advocate should use a signboard or name plate that is a reasonable size.

Not to charge for training; An advocate is not permitted to charge for any training that is provided for someone to be eligible for enrolment. Avoid using name or services for unlawful practice: An advocate may not permit any lay agency to use his name or professional services in connection with any unlawful practice of law. Not to enter appearance without consent of the advocate already engaged: Unless the other advocate has given permission, an advocate cannot enter appearance in a case where another advocate has already been engaged on behalf of a party. But if the advocate fails to provide this consent, they must explain why, and they can only make a subsequent appearance with the court's approval.

Advocates' obligations to their clients:
The advocate's duties to his client are as follows: an advocate has a fiduciary duty to protect the client's interests through honest and ethical means, regardless of the potential for negative outcomes for the advocate or any other parties.

The afore mentioned are just a handful of the crucial codes of conduct that an Indian advocate in practice must adhere to. Honesty, courage, industry, wit, eloquence, judgement, and fellowship are the seven essential qualities that Justice Abbot Parry lists as being essential for a lawyer. He refers to these qualities as the "seven lamps of advocacy."

Other than that, according to Sri Ram Kishore, the panchsheel of the bench are Impartiality, Independence, Integrity and Industry, Judicial activism, and Prayer; those of the bar are Honesty, Industry, Justice, Service, and Philosophy. Among the many responsibilities of advocates, such as those to their clients, courts, the public, their colleagues, and themselves, a few points can be chosen and ranked in order of appropriateness; these are known as the ten commandments of advocates.

• Client duties:
  1. safeguarding the client's interests
  2. accurately assessing the cost of legal counsel and services
• Court duties:
  1. Loyalty and integrity
  2. Case preparation
  3. Public obligations
  4. Service
  5. Faith in the rule of law and justice
• Duties to colleagues:
  1. Fellowship
  2. fairness
  3. obligations to self-systematic study
  4. diligence and caution

The Bar Council of India has established guidelines that serve as a code of conduct for advocates. Broadly speaking, any infraction of these guidelines or the code of conduct is considered professional behaviour. The Supreme Court has continued to expand the term's definition in several rulings.

Statement Of Problem
Being an advocate is a noble, distinguished, and important career. Being an advocate means having a high social status and being looked up to by others as an example for the people in our society. However, there are times when a small number of advocates are found to have acted improperly to satisfy their own selfish desires. In this research paper, the author discusses the ethics and code of conduct that advocates must follow as well as their responsibility to uphold the rights of the public.


Research Question

1. What part do advocates play in educating Indian citizens about justice?
2. What are the codes of ethics and conduct that Indian advocates must adhere to, and are they held responsible for adhering to them?

Hypothesis
Advocacy is a noble profession, but few people are truly skilled in it. It takes extreme discipline, dedication, and hard work. There have been several outstanding supporters in the fraternity whose names are inscribed in gold letters, and they have served as an inspiration to the younger generation to pursue careers in this area. Stricter laws are required to address the fact that corrupt and unethical practices have tarnished this profession on multiple occasions in the present era.

Research Objective & Scope
This research paper tries to explain the origins and development of The Advocates Act, 1961, paying careful attention to the guidelines and standards of behaviour that Advocates must adhere in order to practise the honourable profession of advocacy. The research then seeks to support its assertion by thoroughly comprehending the current state of the profession during the modernising storm that the holy institutions of the judiciary are facing, with the aid of case laws.

Research Methodology
Research can be categorised according to the type of data it uses, the instruments it uses to collect it, how it interprets data that has already been collected, and other factors. The researcher has used the analytical doctrinal method in this research dissertation. Since it is a doctrinal work, pertinent publications, websites, journals, books, and articles have all been examined and analysed. Court rulings have also been thoroughly examined, leading to the logical and sensible conclusion that has been reached.

Legal Frameworks Associated:
A comprehensive piece of legislation that governs legal practice and legal education in India is the Advocates Act of 1961. It calls for the creation of the Bar Council of India and State Bar Councils, along with several disciplinary committees to handle advocate misconduct. Additionally, it contains provisions pertaining to advocates' right to practise as well as their admission and enrolment.

Sections 35 through 44 of Chapter V address the advocates' behaviour. It outlines the Bar Council of India's disciplinary powers as well as the penalties for professional and other misconduct committed by advocates. Misconduct need not only be professional in nature to be subject to the application of section 35 of the Advocates Act. The phrase "professional or other misconduct" is used in this section. Therefore, even behaviour unrelated to one's profession can be considered misconduct, such as being found guilty of a crime even though one did not commit it while working.

There is no reason to limit the definition of misconduct because it has infinite variations. Whether it be professional or otherwise, misbehaviour must be understood in its plain and natural sense. When used in reference to professionals, the term "misconduct" typically connotes an action carried out wilfully and with malice, even though such actions are not intrinsically wrong.

The Bar Council regulates the bar by enforcing disciplinary actions against members and setting guidelines for appropriate behaviour and manners. Additionally, the Council establishes requirements for legal education and recognises universities that offer legal degrees that meet the requirements to become advocates.

The Bar Council of India and each State Bar Council has a disciplinary committee that has the authority to impose sanctions. According to Section 9 of the Advocates Act, 1961, each Bar Council must have a Disciplinary Committee. Each Disciplinary Committee will have three members: two will be chosen by the Council from among its members, and the third will be an advocate co-opted by the Council from among those who meet the requirements outlined in the proviso to subsection (2) of section 3 (i.e., an advocate who has been registered on a State roll for ten years) and who are not Council members. The oldest of the three will be designated as the committee's chairman.

According to Section 35[2], "the State Bar Council shall refer the case for disposal to its disciplinary committee where on receipt of a complaint or otherwise it has reason to believe that any advocate on its roll has been guilty of professional or other misconduct." In addition, the State Bar Council's disciplinary committee will schedule a hearing for the case and make sure the state's advocate general and the implicated advocate are informed.

The State Bar Council's disciplinary committee may decide on a case after providing the concerned advocate and the Advocate-General with a chance to be heard. The Disciplinary Committee may issue the following directives: -Dismiss the complaint or, in cases where the State Bar Council requested the start of the proceedings, order that they be filed.

Reproach the advocate; prohibit the advocate from practicing for as long as it sees fit; Take the advocate's name off the State's list of advocates. Likewise, the Bar Council of India has disciplinary authority under section 36 of the Advocates Act, 1961. When considering any case under this section, the Bar Council of India's disciplinary committee will follow the guidelines outlined in section 35. In addition to the concerned advocate, the Attorney-General of India-who, in the case of the State Bar Council, is the Advocate-General of the State— must also receive notice regarding the Bar Council of India. ix

Anyone who feels wronged by a decision made by the State Bar Council's disciplinary committee under section 35 or by the Advocate-General of the State may file an appeal with the Bar Council of India under section 37 within sixty days of the date the order was communicated to them. This appeal will be considered by the Bar Council of India's disciplinary committee. Additionally, within sixty days after the date the order is communicated to him, any individual who feels that they have been wronged by an order issued by the Attorney-General of India or the Bar Council of India's disciplinary committee under section 36 or section 37 may choose to file a complaint.

Critique
The Advocates Act 1961 was a long-awaited law that consolidated the laws pertaining to legal practitioners, established independent Bar Councils, prescribed a uniform membership requirement, and registered individuals as advocates. But perhaps most importantly, it penalises advocates for professional misconduct and functions as a quasi-judicial body in that context. Except for contempt of court, which is also misconduct, the Bar Council, which was established under the Act, may only be contacted in cases involving professional misconduct on the part of a lawyer. Nevertheless, the Act is criticised for its lack of ability to punish professional and other wrongdoing, as follows:

• The Bar Council of the State will have the same authority to act as the High Court because the act will not grant any right of appeal before the relevant High Courts.
• An advocate cannot file a case from an irate Bar Council of India order and then proceed to the Supreme Court in the regular manner.
   
• Professional and other misconduct were included in the act, but the term misconduct was not defined; instead, the Bar Councils and Supreme Court are free to define and broaden the definition.
   
• The denial of the natural justice principle to a common litigant who has been wronged by the advocate's actions because the Bar Council, the association's body, decides cases in which the respondent is one of its own members. The idea that a man cannot sit as a judge in his own case is refuted by this. If a layperson files a lawsuit under service deficiency, they must contact the appropriate forums set up under the Consumer Protection Act of 1986 in order to seek financial relief for the harm caused by such misconduct.
   
• The freedom of speech and expression guaranteed by Article 19(1) (a) as well as the right to practise a trade or other professional activity are occasionally violated by legislation depending on the circumstances.

Duties Of An Advocate:

Members of the profession are expected to conduct themselves according to several canons of etiquette and conduct. As a result, to ensure that the advocates operate in the profession in a proper and orderly manner, certain obligations have been placed upon them. A legal ix Professional Misconducts of Advocates in India by Lex Forti Legal News Network available in Contemporary Legal issue, Research Column, 17th September 2020. practitioner is expected to perform the following tasks:

• Duty towards opposite party:
  • The advocate must manage the case with fairness and respect, not just for his own client but also for the court and the opposing party.
  • Negotiation and communication with the other parties regarding the topic and other controversy-related details are required, but only through the opposing party's advocate.
  • Even if the promise is not put in writing, the advocate should honour any commitments he made to the opposing party.
  • He must never attempt to cause harm to the other party or his attorney, either inside or outside the courthouse.
     
• Duty towards his client:
  • There is a strong fiduciary bond between the client and the advocate. The attorney must reasonably and thoughtfully assess the cost of the associated legal services and advice, charging no more than what is reasonable.
  • In addition, it is the Advocate's responsibility to bravely advance the client's interests by just and moral means.
  • He should not back out of a case that he has already agreed to take on. Should he do so, he must give the client a valid and justifiable reason. He is required to return the fee he received from the case after withdrawing. In no circumstances may an advocate abuse the client's confidence and trust in him.
     
• Being truthful and polite is an advocate's primary obligation to the court. It would be considered professional misconduct if he were to act disrespectfully.
  • Before he presents the case, he needs to prepare it completely. He must act with the highest dignity and respect for himself while making his case.
  • He cannot attempt to use any unethical or unlawful methods to sway the court's rulings. Additionally, he ought to refrain from attempting to speak with a judge about an ongoing case.
  • The Advocate shall always appear in the appropriate attire and maintain a presentable appearance.
     
• Duty to Provide Legal Aid:
  • Attorneys should always remember that anyone in immediate need of legal representation has the right to look for a legal assistant, even if they are unable to pay the attorney's fees in full or adequately.
  • One of the most significant duties an advocate has to the community is to provide free assistance to the marginalised and impoverished segments of the population.
     
• Employment Restrictions:
  • An advocate may be a partner in crime in any company that is in business, but he may not personally engage in any other business. Nonetheless, the Bar Council states that the nature of the business cannot be at odds with the respect for the profession.
  • He is not permitted to work as a salaried employee of any government agency, individual, business, or firm while he is actively practicing law.
  • An advocate may carry on a family business that he inherited, but he is not allowed to take an active role in its management. In a similar vein, he is permitted to own stock in a company he inherited, but he is not permitted to oversee it actively and personally.

Landmark Judgments:

1. Sambhu Yadav v/s Hanuman Khatry x:
   In this case, the complainant lodged a grievance against an advocate who was registered with the State Bar Council of Rajasthan. The subject of the complaint was bribery. The complaint states that during the suit appearance, the attorney requested in writing a bribe of Rs. 10,000 to sway the judge to their side and secure an order that would benefit them. The Disciplinary Committee stated that the lawyer was completely unfit to practice law due to his actions. The Supreme Court upheld the Bar Council's decision, declaring that practicing law is not a trade or a business. To ensure justice, it is the Advocates' responsibility to uphold the integrity and morality associated with their line of work and to combat corruption.
    
2. M. Murlixiii v. Noratanmal Chaurasia xi:
   In this case, the Supreme Court ruled that while the word "misconduct" is not defined in the Advocates Act, misconduct is depicted and includes a breach of discipline. After assaulting the complainant with a kick, the advocate in this case requested that the complainant not pursue the case further. The Supreme Court declared that attorneys have a duty to adhere to the standards and guidelines regarding conduct. Such behaviour was deemed inappropriate for any professional setting.
    
3. Suo Motto Enquiry v/s Lal Balwani xii:
   Here, the advocate appeared in the Apex Court, opened his shoes, threw them, and yelled slogans. Two charges were brought against him: professional misconduct and disrespect. The Supreme Court convicted him of his crimes and sentenced him to four months in prison and a fine of Rs. 2000. His name was later to be removed from the State roll after the Bar Council of India and the Disciplinary Committee found him guilty of professional misconduct.
    
4. BCM v/s M. Dabholkar xiii:
   It was observed that the attorneys who positioned themselves at the Magistrate's court entrance in an attempt to identify and pursue potential plaintiffs, typically caused difficulties for both sides. The Disciplinary Committee noted that professional misconduct was evident in this instance. It further declared that a book or regulation could not contain professional ethics. Misconduct involving solicitors must therefore be understood in a dynamic and context-specific way that captures the advocate's duty to the public.
    
5. SCBA v/s UOI xiv:
   Taking up complaints about advocates is one of the State Bar Council's most important responsibilities when it comes to their behaviour. It is the responsibility of the States' Bar Council to forward any suspicions of misconduct regarding an advocate to the State Bar's Disciplinary Committee for resolution. Should the Council fail to initiate legal action against the advocate despite being informed by the Court, the Court shall exercise its authority under Section 38 by assuming control of the Bar's proceedings and issuing appropriate directives.

The High Courts are exempt from Section 38's appellate powers.

Conclusion:
"Lawyers are the foot soldiers of our Constitution." - Rennard Strickland

The legal profession is extremely important. Since practicing law is seen as a noble and moral profession, upholding professional ethics is crucial. There have been cases where a lawyer tried to kill his own client. Therefore, it is imperative to ensure that those with such criminal tendencies are prohibited from shielding others from punishment. There are a few rules that guarantee the individual enrolling as an advocate has no criminal history, but they are insufficient to guarantee the individual's propensity for crime.

As a result, it is crucial that lawmakers draft and amend laws pertaining to the different kinds of misconducts in this field. A lawyer's job is to shield clients from punishment; it is not appropriate for someone of this calibre to engage in such wrongdoing themselves. To educate legal practitioners, the Bar Councils in every state are required to hold annual education programmes about the dos and don'ts of the profession. Reminding the Advocates of their various professional responsibilities is equally important. To set an example for the other Advocates, severe penalties must be meted out to those found guilty of misconduct.

End-Notes:

1. Bar Council of Maharashtra vs M. V. Dabholkar, available at https://indiankanoon.org/doc/276363/
2. AIR 1992 SC 2188
3. AIR 1979 SC 281
4. AIR 1965 Mys. 28
5. D. Dalal versus SBI AIR 2001 SC 2028
6. Professional Misconduct, available at https://easyadvocacy.com/EADigest/Professional-Misconduct-and-ItsImplications-Under-Advocates-Act-1961 (Visited on 7 th October, 2020)
7. AIR 1935 Cal. 547
10. Landmark judgements on Misconduct, available at https://www.pathlegal.in/List-of-Landmark-Judgements:
    Misconduct-of-an-advocate-and-I-blog-1158310 (Visited on 8th October,2020
11. Supra note 8
12. Ibid
13. Ibid
14. Supra Note 8