SDT: Significant foreseeable harm
A solicitor who only qualified because he lied about having passed certain tests – and even forged certificates to convince the Solicitors Regulation Authority (SRA) – has been struck off.
Muhammad Ifzal’s conduct had been “a complete departure from the standards of integrity, probity and trustworthiness expected of him”, said the Solicitors Disciplinary Tribunal (SDT).
Mr Ifzal was born in 1975 and admitted to the roll in 2015, although he has not held a practising certificate.
In 2011, the SRA issued him with a certificate of eligibility under the Qualified Lawyers Transfer Regulations, which meant he could qualified in England and Wales subject to passing four tests – in litigation, property, principles of common law, and professional conduct and accounts.
The ruling did not say what his previous qualification was that meant he was qualifying through the transfer regulations.
Mr Ifzal undertook the litigation test with Kaplan Altior and the other three with BPP University College.
In February 2015, he applied for admission to the roll and supplied certified copies of certificates purportedly from BPP saying he had passed the three tests. He was admitted in April 2015.
However, in September 2017, BPP informed the SRA that he had actually failed the property and common law tests, the latter twice, and that all three certificates were forgeries.
The tribunal noted that the certificate for the common law test had spelling and grammatical errors.
“Members of the public would not trust a solicitor who had been admitted to the roll on the basis of false information,” it said, ruling that his actions were dishonest and lacked integrity.
The SDT added that the “foreseeable harm arising from his conduct was significant” – had he sought a practising certificate, it would have been granted and he would have been able to represent clients.
Mr Ifzal did not acknowledge or respond to the tribunal proceedings, which continued in his absence given what it considered his deliberate lack of engagement.
The SDT was also satisfied that it had jurisdiction to determine the case even though the actions took place before Mr Ifzal was admitted, because he was a solicitor at the time of the proceedings.