Kulwant Singh Manak Fails in Bid to Remove Solicitor Practising Restrictions

What did the Tribunal decide?

In Solicitors Regulation Authority Ltd v Kulwant Singh Manak (Solicitors Disciplinary Tribunal, Case No. 12919-2026), the Tribunal refused Manak’s application to remove the conditions imposed following disciplinary proceedings in 2017 and 2018. The judgment was dated 23 October 2026.

The application was made under Rule 18 of the Solicitors (Disciplinary Proceedings) Rules 2019. The Tribunal held that Manak, as the person seeking the removal of existing restrictions, had to establish the basis on which they should be varied or removed. It emphasised that this did not require him to reopen or relitigate the findings made in the original proceedings. The question was whether the evidence now before it provided sufficient grounds for changing the restrictions.

The Tribunal concluded that it was not satisfied that removing or varying the conditions would adequately protect the public or maintain public confidence in the solicitors’ profession. The application was therefore dismissed.

What practising restrictions were in place?

Manak was admitted as a solicitor on 15 February 1993. The earlier disciplinary proceedings concerned, among other matters, the handling of client money, failures to comply with the Solicitors’ Accounts Rules, obtaining a loan from a client without appropriate safeguards, inadequate supervision and findings that his conduct lacked integrity.

On 12 January 2018, the Tribunal suspended him from practice for two years and imposed restrictions to apply after the suspension. Following an appeal, the High Court quashed three of the original restrictions. The remaining restrictions prevented him from practising as a sole practitioner or as the sole manager or owner of an authorised body; acting as a partner or member of specified legal entities; and acting as a Compliance Officer for Legal Practice (COLP) or Compliance Officer for Finance and Administration (COFA).

When Manak later applied for practising certificates, the SRA granted them subject to conditions reflecting those restrictions. He had worked as a consultant solicitor at Maya & Co Solicitors since January 2022, according to the judgment.

1. 15 February 1993 Manak admitted to the Roll of Solicitors.
2. 12 January 2018 Tribunal imposed a two-year suspension and practising restrictions.
3. 31 July 2018 High Court quashed three of the original restrictions.
4. 23 January 2020 SRA decision granted a practising certificate subject to conditions.
5. 2 January 2022 Manak began working as a consultant solicitor at Maya & Co, as recorded in the judgment.
6. 13 August 2026 Tribunal heard the application to remove the conditions.
7. 23 October 2026 Tribunal refused the application and ordered £6,670 in costs.

Why was the application refused?

The Tribunal considered whether the evidence showed that the restrictions continued to serve a necessary regulatory purpose. It took account of the need to protect the public and maintain public confidence in the profession, alongside the factors identified in the relevant guidance.

It found that the material provided did not give a sufficiently clear picture of Manak’s present professional position, the responsibilities he carried out, the safeguards surrounding his work or what he intended to do in the future. The Tribunal was also not satisfied that the evidence demonstrated how the risks identified in the original disciplinary proceedings had been adequately addressed.

The Tribunal recognised that a significant period had passed since the misconduct and that Manak had returned to practice after his suspension. However, it said that the passage of time and continued practice, without more, did not establish that the restrictions were no longer necessary.

What evidence did the Tribunal consider?

Evidence of current employment and practice. Manak told the Tribunal that he worked as a consultant solicitor at Maya & Co, undertaking matters including commercial leases, wills and probate. He also described reviewing work undertaken by a junior solicitor and a trainee. However, he did not provide documentary confirmation of his position or supporting evidence from the firm’s principal, another employee, a solicitor or a client. The Tribunal considered that evidence about his role and the arrangements under which he practised would have been directly relevant.

Future professional intentions. The Tribunal said there was no clear evidence about whether Manak intended to remain in his existing role, seek greater responsibility or practise in a capacity that would engage the restrictions. This left it without a sufficiently clear basis on which to assess the practical implications of removing the conditions.

Training and professional development. The documentary evidence included certificates for three courses completed in October 2024. The certificates gave limited information about the course content or what had been learned. Manak described the courses as a refresher and said the original proceedings had taught him that regulatory requirements must be followed without exception. The Tribunal took that explanation into account but considered it general, and not sufficiently detailed to show how the training addressed the risks arising from the original misconduct or how the learning had been applied in practice.

Character reference. The Tribunal considered a reference provided in support of the application. It was supportive but general, offering little specific evidence of rehabilitation, professional development since the original proceedings or how the matters that led to the restrictions had been addressed.

Alleged practical impact of the restrictions. Manak relied on correspondence concerning Land Registry verification, a dispute about a will and proposed commercial instructions. The Tribunal was not satisfied that these documents established that the restrictions themselves had caused him to lose work. It considered that some of the difficulties related to his publicly available disciplinary history, which would remain irrespective of whether the practising restrictions were removed.

“Neither the passage of time nor the fact that the Applicant had continued to practise was, without more evidence, sufficient to establish that the restrictions were no longer necessary.”

Solicitors Disciplinary Tribunal, judgment, paragraph 70

What was the costs order?

The SRA applied for its costs of responding to the application, seeking £6,670. Manak opposed the application, arguing that he had been told during practising certificate renewals that the conditions had been imposed by the Tribunal and could be removed only through an application to it.

The Tribunal was not satisfied that the evidence showed the SRA had directed him to bring the application. It found that the SRA had been required to participate in the proceedings and that the costs claimed were reasonable and proportionate. It therefore ordered Manak to pay the SRA’s costs, fixed at £6,670.

What does the decision mean for solicitors?

The decision illustrates the importance of providing focused, current and independently supported evidence when applying to vary or remove practising restrictions. Where an application concerns management, supervision or compliance responsibilities, evidence about the applicant’s actual role, the firm’s oversight arrangements and the safeguards in place may be central to the Tribunal’s assessment.

It also shows that general statements about insight, training and professional experience may carry limited weight if they are not connected to the specific risks identified in the original proceedings. In this case, the Tribunal was looking for evidence explaining what had changed, how the applicant had addressed the earlier concerns and what the proposed position would involve.

The Tribunal’s decision was based on the evidence in this application. It did not reopen the original disciplinary findings; it determined that the material presented was insufficient to justify removing the restrictions.