HEARING DIVISION

Date: May 22, 2026

Tribunal File No.: 25H-033

BETWEEN:

Parmal Singh

Applicant

and -

Law Society of Ontario

Respondent

Before: Kathleen Lickers (chair), Gisele Chretien, Murray Klippenstein

Heard: March 11-12, 2026, by videoconference

Appearances:

Applicant, self-represented

Jasmeet Kala, for the respondent

Summary:

SINGH – Licensing – Good Character – Examination Cheating Scandal – Misrepresentation – The panel found that the Licence Applicant made deliberately false and misleading representations to the Law Society and was therefore deemed by s 8(2) of By-Law 4 to have not met the requirements for licensing – The Licence Applicant also thereby failed to meet the good character requirement – The Licence Applicant’s application was dismissed.

REASONS FOR DECISION ON LICENSING

1Kathleen Lickers (for the panel):– The Law Society of Ontario referred Parmal Singh’s application for licence to a hearing under s 27(4) of the Law Society Act, RSO 1990, c L.8 (the Act).

2Mr. Singh (the applicant) was born in 1984 and obtained a law degree in India, where he practised law for approximately 14 years. He immigrated to Canada in 2022.

3The applicant submitted an application to the Law Society of Ontario in September 2021 for a Class L1 licence to practise law. He wrote the solicitor exam on November 19, 2021. The Law Society initiated a good character investigation after receiving information about the applicant in relation to allegations of widespread cheating that occurred on the Law Society’s November 2021 licensing exams.

4Following the Law Society’s investigation regarding Mr. Singh, it issued a notice of referral for hearing (NORH) on March 24, 2025.

5The hearing proceeded by way of an agreed statement of facts (ASF) and joint book of documents. The parties agreed that because of the admissions in the ASF, neither party needed to prove the facts already admitted, but that they could each present additional evidence consistent with the facts as agreed. In addition to the testimony of the applicant, Mr. Singh called a number of individuals as character witnesses.

6The Law Society makes this referral for hearing for us to decide:

Whether the applicant made false or misleading representations on or in connection with his application for licence contrary to s 8(2) of By-Law 4. If so, he is deemed not to have met the licensing requirements.
If not, then is the applicant currently of good character.

7It is the Law Society’s position that Mr. Singh’s application for licence should be denied for making false or misleading declarations in connection with his application related to the November 2021 licensing exams and therefore he has not met the requirements for licence. Relatedly, it is the Law Society’s position that the applicant is not currently of good character. His application for licensing should therefore be denied.

8The applicant admits that he was in possession of cheating materials obtained in advance of taking the November 2021 solicitor exam and that he reviewed these materials in advance of taking the exam.

9The applicant admits that prior to writing the November 2021 solicitor exam, he showed FF, another exam taker, a list of questions and answers he received from the study group, which included screen shots of a prior solicitor exam.

10During the LSO investigations into the applicant’s character, he was given multiple opportunities to disclose his possession, distribution, and use of unauthorized materials, as admitted above. Instead, he was not immediately forthcoming to the Law Society and misrepresented his knowledge when writing the November 2021 solicitor exam. He acknowledges that he was not forthcoming.

11Mr. Singh has subsequently rewritten and passed the licensing exams in 2023. The consequences for him arise not from the rewritten exams, but from the good character and integrity implications of his false and misleading representations related to the November 2021 solicitor exam.

12We find that Mr. Singh’s application for licence should be denied because he made deliberately false and misleading representations to the Law Society and is deemed by s 8(2) of By-Law 4 to have not met the requirements for licence, and for his failure to meet the good character requirement.

13These are our reasons.

REGISTRATION IN THE LAW SOCIETY’S LAWYER LICENSING PROCESS

14All candidates who seek to apply for a licence with the Law Society must complete a registration form. This form includes a section entitled “Good Character”, where candidates must answer yes or no and provide supporting documentation regarding a series of questions addressing their current character.

15This section also requires a candidate to immediately notify the Law Society in writing if any of their answers to any of the questions change. The candidate is also informed that upon successfully completing the lawyer licensing process, they will be required to complete and sign an undertaking that they have maintained good character standing throughout the process and up to the day of their call.

16The registration form also includes a “Declaration and Obligations” section which states, in part:

I confirm to the Law Society of Ontario that I will perform all of my obligations as a candidate and obey all the Rules of Professional Conduct, other rules, regulations, policies and requirements of the Law Society.

I further understand that if I do not comply with the requirements of the Law Society, my candidate status may be revoked.

17One of the requirements of a Class L1 licence to practise law is the completion of the applicable licensing exams. There are two licensing exams in the Law Society of Ontario’s licensing process: the barrister exam and the solicitor exam. The Law Society offers these exams three times a year: winter, summer and fall.

LSO’S LICENSING EXAMS

18Once a candidate has applied for licensing and selected an exam sitting, they are provided with access to study materials, which are prepared each year by the Law Society. Candidates do not require additional study material to prepare for an exam.

19The Law Society maintains strict confidentiality and security of the contents of the study material. Candidates are strictly prohibited from disclosing such materials to any person or organization, or reproducing or publishing them by any means.

20The exams are open book and all of the questions are multiple choice. Each exam is 160 questions and delivered in two parts. Each question contains four answer options, one that is the correct answer and three that are incorrect.

21Exam questions are maintained by the Law Society in a confidential examination bank and may be used on more than one exam. Exams are developed with reference to this bank.

22The exams contain both “experimental” and “operational” questions. Experimental questions are those that appear on an exam to be tested for statistical purposes. They do not count toward a candidate’s score on an exam. Candidates are made aware that each exam may contain experimental questions but do not know for certain which questions, if any, are experimental.

23Operational questions are those that met the required statistical parameters during a past experimental phase and are counted toward a candidate’s score.

24The Law Society develops several different versions of each exam for each sitting. While the operational questions are all the same on each of the different versions, they appear in different order depending on the version. The experimental questions are different on each exam.

25Post-exams, the Law Society works with a psychometric service provider, Performance Assessment Group, Inc., to evaluate whether experimental questions can become operational on future exams and whether operational questions are performing as expected so they can count toward the passing score.

The Candidate Agreement and Licensing Examination Protocol

26As a precondition to writing licensing exams, candidates are required to agree to comply with the Law Society’s Licensing Examination Rules and Protocol (Protocol) and agree to the terms of the Candidate Agreement.

27The Protocol and Candidate Agreement prohibit candidates from disclosing any examination content to others, and from obtaining and using prior exam content to attempt to assist them in passing the exams they write. Candidates also agree to advise the Law Society in writing immediately should they become aware that other persons are disseminating, distributing, transmitting, disclosing, publishing, streaming, reproducing, copying, altering, receiving, obtaining, giving, or retaining exam content.

The November 2021 Licensing Exams

28In response to the Covid-19 pandemic, in the winter of 2020-21 the Law Society transitioned from in-person to online exams and retained Paradigm Testing LLC (Paradigm) to deliver the online exams.

29As a result of this change in exam delivery, candidates could write the exams from virtually any location in the world on their own computers and could choose from multiple times and days. Paradigm implemented security measures such that when the exam software was running, candidates could not use their computer for other purposes.

30In November 2021, the solicitor exam was available online each day between November 16 to 19, 2021. There were five English-language versions of each exam with 150 operational questions appearing in a differing order for each version and 10 different experimental questions.

31During the post-exam review, Paradigm advised the Law Society that two candidates in the November exams had connected from the same IP address, had moved unusually quickly through the solicitor exam, had significant periods of inaction, and had made very few changes to their responses. The applicant was one of these individuals; the other individual is anonymized as FF.

32The Law Society looked further into the applicant’s and FF’s exam answers and observed that they both answered some questions extremely quickly (taking five to ten seconds), and the experimental questions tended to take longer to answer. They also shared 13 incorrect answers. Finally, they each listed the other as their emergency contact in their application.

33The Law Society used the 13 incorrect answers in common between the applicant and FF to flag other candidates for further assessment.

Information received regarding the November 2021 licensing exams

34On December 21, 2021 the Law Society received an external tip that there may have been cheating on the November 2021 barrister exams. Two documents were provided to the Law Society which were said to have been provided to a licensing candidate who had taken the barrister exam in November 2021. The documents contained answers to many of the operational and experimental questions that had been asked in the first version of the exam.¹

35The Law Society later received cheating materials (Bundle 3 and 18-21) regarding the November 2021 solicitor exam.

NEG/NCA Exam Guru

36NEG, also referred to as NCA Exam Guru, is a tutoring service based in Mississauga, Ontario offering courses for the Law Society licensing exams, as well as the National Candidate exams and general legal knowledge courses for practitioners. NEG has a public Facebook group where former and current students interacted. Candidates who registered for the course and paid the associated fee were also added by NEG to a WhatsApp group chat and a Skype group. With respect to the November 2021 solicitor exam, both were entitled “Reg Sol Nov 21”.

37The applicant was enrolled in NEG’s tutoring service and was a member of the “Reg Sol Nov 21” WhatsApp and Skype groups. He participated in group discussions where Law Society exam content was discussed.

38The principal of NEG is Aamer Chaudry, an unsuccessful former candidate in the Law Society of Ontario’s licensing process.

39NEG offered classes via Zoom for the barrister and solicitor course. The Zoom lectures were recorded and made available for candidates on the NEG website. As a result, some students attended lectures via live Zoom class, whereas others watched recordings.

40Lectures were conducted by Chaudry and a lawyer licensee named Farzaneh Mukherjee. In the weeks leading up to the November solicitor exam, Chaudry and Mukherjee conducted “workshops” to answer questions and go over practice exam questions. The last solicitor workshop was held November 13, 2021.

41The WhatsApp group was used to discuss legal issues and exam preparation tips, as well as to exchange documents and practice material beyond the Law Society study materials. The Skype group was primarily used to distribute Zoom log-in information about upcoming lectures but was also used to share documents with candidates.

Forensic testing services

42In light of the evidence of possible cheating on the November 2021 exams, the Law Society retained Caveon Test Security (Caveon), a forensic testing services provider, to analyze the results of all candidates who had written the licensing exams in November 2021 and determine if there were any statistical anomalies to indicate potential fraud had occurred.

43In its final report, Caveon concluded that cheating had been widespread during the November 2021 licensing exams. Caveon compared candidates’ answers to the cheating keys that had been discovered. Out of the 843 candidates that wrote the solicitor exam, Caveon recommended the invalidation of 83 results, or approximately 9% of all solicitor exam results.

44Beyond the statistical result, Caveon recommended the Law Society assess other forms of evidence to confirm or explain the results such as cheating keys that had been distributed to students, social media groups, past and future exam scores and videos discussing distribution of exam content. The cheating keys that had been discovered were described as “Bundle 3 Braindump” and the “18-21 Braindump”.

45Caveon recommended the applicant’s solicitor exam results be invalidated based on its statistical analysis and its additional forensic analysis revealing that it was 100 times more likely that he used cheating material than not.

Admissions

46The parties filed the ASF with supporting documents as agreed, including as to their authenticity.

47Mr. Singh sought to introduce documents not included in the ASF and not previously provided to the Law Society, contrary to Rule 10.5 of the Tribunal Rules and Practice and Procedure. Rule 10.5 requires each party to provide all anticipated witness statements and documentary evidence within prescribed time periods of a hearing commencing. Mr. Singh was specifically alerted to this Rule during pre-hearing conferences. We denied admission of these documents pursuant to Rule 10.5.

48The Law Society relies upon paras 9-10 of the ASF where the applicant accepts the jurisdiction of the Tribunal to make findings pursuant to s 8(2) of By-Law 4 and s 27(2) of the Act and accepts that the Tribunal may use or rely on the ASF in making its findings.

49As part of his licensing application, the applicant signed the Declaration and Obligations section of the registration form. He wrote the solicitor exam while in India on November 19, 2021, the last day of the solicitor exams. He scored 97.66%. This result was later deemed void by the Law Society after Caveon completed its forensic analysis.

50Following the November 2021 exams, Paradigm provided information about the applicant’s and FF’s exam sitting and results. For the solicitor exam Paradigm advised that they:

had connected from the same IP address in India;
commenced their exams within 15 minutes of each other;
had very fast response times;
had significant periods of inaction;
made very few changes to their responses; and
had very similar responses.

51With respect to the applicant in particular, Paradigm advised that:

94% of his exam answers matched FF’s exam answers;
he spent time clicking through nearly every question;
there were large gaps of time that he was idle during the exam;
he spent mostly less than 20 seconds per question; and
he finished the exam in less than half of the allotted time.

52On December 13, 2021, the Investigation Services department was instructed to investigate and the applicant was advised of this good character investigation by letter of January 12, 2022. The letter described the allegations made by Paradigm and the applicant was asked for his submissions.

53On January 17, 2022, the applicant denied any knowledge of cheating or any personal wrongdoing to the LSO, and:

denied any wrongdoing, noting he “had not done anything which stands inconsistent or in violation of the terms and conditions of solicitor examination”;
expressed shock and misery to know his conduct had raised concerns;
represented that he came to know about FF in January 2020 from a WhatsApp group for people who applied for a provincial program in Saskatchewan;
represented that he and FF studied together and were constantly in touch;
represented that he wrote the November 2021 solicitor exam in FF’s apartment and that FF had been in another room in the same apartment;
represented that there were no gaps of time where he had been idle during the exam but that if any were identified, it was because he had been looking for answers in the materials or thinking;
attributed matching responses to FF as being a “mere coincidence” noting “it is quite possible in multiple choice questions that right answers match with other students”;
attributed his fast test-taking to his preparation and professional experience;
found the questions on the exam “convenient” and was “very confident regarding the answers”.

54In July and August 2022, the Law Society communicated Caveon’s analysis of his November 2021 exam results in detail to the applicant and sought his response as well as his knowledge of or involvement with NEG. The applicant was also asked if he wished to revise his initial January 2022 response to the LSO.

55On August 8, 2022, the applicant responded again to the LSO to deny any knowledge of cheating, stating:

after he completed his NCA exams, he found out about Mr. Chaudhry online and contacted him for solicitor and barrister exam coaching;
he paid for and took online NEG classes;
that Mr. Chaudhry and his team were “a guiding light” and he followed Mr. Chaudhry “blindly”;
he was a member of a Skype group and WhatsApp group;
he received study materials with questions from the email address vikasarun90@gmail.com on October 26, 2021, and attached a copy of the email itself;
the email he received from vikasarun90@gmail.com auto expired;
he used the content of the email he received from vikasarun90@gmail.com and was “not at all aware that the content was unauthorized”;
he thanked Chaudhry and another individual after writing his November 2021 solicitor exam.

56The Law Society interviewed the applicant on September 16, 2024, at which time he made admissions for the first time and provided further information with respect to cheating on the November 2021 solicitor exam. Specifically, he stated that:

He was shown the 18-21 Braindump and recognized some of the questions from the 18-21 Braindump as also having appeared on his November 2021 solicitor exam.
He received the 18-21 Braindump two or three days prior to writing his exam.
He tried to memorize the 18-21 Braindump because he was told that it was important.
When he was writing the November 2021 solicitor exam, he realized at that time that the answers on the exam matched the answers in the 18-21 Braindump and that that was why he was able to answer the questions so quickly.
On the second part of the exam, he would look just at the answer options because the answers from the cheating key were fresh in his memory, and he did not completely read all of the questions.
The 18-21 Braindump was unique from other materials and practice questions he received from NEG because it only had answers.
Both he and FF had the 18-21 Braindump.
He agreed with Caveon’s analysis and acknowledged that he used unauthorized licensing exam content.
He believed the November 2021 licensing exams were compromised and that somebody had gained access to the exam material.

57During the September 16, 2024 interview, the applicant admitted that he was not initially forthcoming with the LSO during the good character investigation, and admitted that he should have raised the concerns about the exam at the time he wrote the exam or after he wrote it, but did not do so. When asked during the interview why he did not advise the LSO about his involvement with NEG in his prior representations to the LSO, the applicant stated:

My initial representation...I just got, you know, my judgment got clouded or I could not properly decide how to respond and what to respond to that point. And that’s why I, I regret to that. I just replied to it that with the, you know, with the intent of becoming over smart, you can say. But later I realized that though that time also, I realized that, you know, the mistake had happened, but I was just, because I was thinking of starting my career here from the fresh, because I, I was planning to come as a PR in Canada with the family. So I just got, you know, too much, you know, dilemmatic or I could not decide properly that time. That's why I just gave that reply.

But later on, in August reply, I, after Caveon report and all, I realized then I, I just apologized and that, you know, I have made a mistake, so.

58On March 14, 2025, the applicant was advised that the investigation had been transferred to the Litigation Services department.

Findings regarding By-Law 4, s 8(2)

59Section 8(2) of By-Law 4 provides that:

An applicant who makes any false or misleading representation or declaration on or in connection with an application for licence, by commission or omission, is deemed thereafter not to meet, and not to have met, the requirements for the issuance of any licence under the Act.

60Section 8(2) seeks to ensure candour by applicants and addresses representations “on or in connection with an application for a licence”: Jariwala v Law Society of Ontario, 2025 ONLSTH 181. In Levenson v Law Society of Upper Canada, 2009 ONLSHP 98, the Tribunal explained that s 8(2) has two aspects:

… An applicant is expected to self-report events that might bear upon his or her character. While the Society has the power to investigate any applicant, there is no doubt that in a self-reporting regime, the Society is heavily reliant on the candour of an applicant. Moreover, even if the Society is aware of an applicant’s history or can easily ascertain it, candour in the application process is also an important badge of an applicant’s good character. Conversely, deliberate suppression of information in the application process is an obvious indication of lack of good character.

61Since Law Society of Upper Canada v Stewart, 2012 ONLSAP 30, it has been clear that, while it is not explicit in s 8(2), the false or misleading representation or declaration referred to in that section must be “deliberate”, with deliberate being defined as either knowing it to be false or misleading, or being reckless or willfully blind with respect to the truth: Dumanian v Law Society of Ontario, 2024 ONLSTA 7 at para 53; Jariwala, above at para 95.

62The applicant signed the Declaration and Obligations section of the registration form where he pledged compliance as a licensing candidate to obey “all the Rules of Professional Conduct, other rules, regulations, policies and requirements of the Law Society.” Further, as a pre-condition to writing the licensing exams, he pledged to comply with the Law Society’s Licensing Examination Rules and Protocol and agreed to the terms of the Candidate Agreement which expressly prohibited cheating.

63While under investigation, his written representations to the Law Society on at least January 17 and August 8, 2022 deny knowledge of unauthorized exam material or any wrongdoing. In those responses he stated that the fact that his exam responses matched with those of FF was “mere coincidence”, that his fast test-taking was due to his preparation and professional experience, and that he was “not at all aware that the content (study material from NEG) was unauthorized”. All of these statements were false.

64In January 2023, the applicant sought to re-enter the licensing process and attached a letter to the Law Society in support of his request. In this letter the applicant represented that ”he received study materials with sample questions from vikasarum90@gmail.com and used the content of the email. He was not aware that the content was unauthorized. Had he known, he would not have referred to it.”

65While the applicant would ultimately be granted permission to rewrite the solicitor exam in November 2023 (and pass with a score of 68.84%) and the barrister exam in June 2024 (and pass with a score of 71.23%), the ensuing efforts of the applicant to satisfy all licensing requirements, including experiential training, are not before us.

66Although Mr. Singh has passed the licensing exams, this does not erase his initial dishonesty. The consequences for him arise not from the rewritten exams, but from the good character and integrity implications of his false and misleading representations related to the November 2021 solicitor exam.

67As referred to above, on September 16, 2024, the applicant was interviewed by the Law Society investigator. During this interview, the applicant admitted that he was in possession of cheating material when he wrote the solicitor exam, that he knew that the “18-21 Braindump” cheating key contained only answers to the solicitor exam and that he tried to memorize the cheating key. He stated that he answered questions rapidly because they were “fresh in his memory” and that he often did not read the full questions, just the answer options. He agreed with Caveon’s analysis and acknowledged that he used the cheating keys when he wrote the solicitor exam on November 19, 2021. He admitted that he failed to disclose this earlier.

68These admissions in September 2024 reveal that the previous representations over time in 2022 and in January 2023 were false, and permit a finding that the earlier denials were deliberate: Dumanian.

69We find the applicant failed to be honest and forthright in not immediately disclosing his possession of cheating material, contrary to his obligations to the Law Society. Further we find he deliberately mispresented his knowledge about, and his use of, the cheating material and mislead the Law Society in that regard.

70The applicant’s deliberately false and misleading representations to the Law Society are in clear breach of s 8(2) of By-Law 4 and he is therefore deemed by that By-Law not to have met the requirements for a licence under the Act.

71It is the Law Society’s position that this hearing may be decided solely by a finding of breach of s 8(2) of By-Law 4, as above, since if we find a breach of s 8(2), we have no discretion and the application must be dismissed: Stewart at para 25.

Application for Licence Refused

72In Jariwala, the Tribunal considered the application of a licensing candidate who was also involved in cheating during the November 2021 solicitor exam and considered as a consequence the alleged breach of s 8(2) of By-Law 4. At para 99, Jariwala was unequivocal:

Section 8(2) effectively deems the maker of a deliberate misrepresentation in the application process not to be of good character. This is, strictly speaking, unnecessary, given that good character is required by the Act. But s. 8(2) removes any doubt that a deliberate misrepresentation demonstrates the absence of good character.

73Our finding of misrepresentation under s 8(2) of By-Law 4 necessarily results in a finding that the applicant does not meet the licensing requirements, including the good character requirement, leaving no discretion. Stewart at para 25; Jariwala at para 99. The application for a licence is refused.

Footnotes

This widespread cheating has resulted in a number of candidates being referred for a hearing at the Tribunal. The same details regarding how the Law Society became aware of the cheating during the November 2021 licensing exams have been set out: Singh v Law Society of Ontario, 2026 ONLSTH 10; Saran v Law Society of Ontario, 2025 ONLSTH 7, Butler v Law Society of Ontario, 2025 ONLSTH 91, Kaur v Law Society of Ontario, 2025 ONLSTH 108.

Parmal Singh v. Law Society of Ontario, 2026 ONLSTH 100

Case Summary