LAW SOCIETY TRIBUNAL

APPEAL DIVISION

Date: May 21, 2026

Tribunal File No.: 25A-023

BETWEEN:

Sumeet Sood

Appellant

• and -

Law Society of Ontario

Respondent in appeal

Before: Teresa Donnelly (chair), Margaret Leighton, Geneviève Painchaud, Natalia Rodriguez, Margaret Waddell

Heard: March 16, 2026, by videoconference

Appearances:

Appellant, self-represented

Owen Minns, for the respondent in appeal

Summary:

SOOD – Appeal – The appellant appealed the revocation of his licence – Given the hearing panel’s findings, which included participation in mortgage fraud, the presumptive penalty of revocation applied – The hearing panel did not err in law or in fact and the presumptive penalty of revocation was not disproportionate – The appeal was dismissed.

REASONS FOR DECISION

1Natalia Rodriguez (for the panel):– In this appeal, Sumeet Sood (the appellant) appeals from an order of the Hearing Division revoking his licence and ordering $26,000 costs against him. The Hearing Division found that the appellant, along with another lawyer licensee, Pawanjeet Singh Mann, had each engaged in professional misconduct by knowingly assisting fraud or dishonesty in connection with interrelated real estate and mortgage work for a client they had in common.¹

2This appeal does not relate to Mr. Mann.

3The appellant raises four grounds of appeal:

1. The hearing panel erred in law and fact by finding “knowing assistance” without proof of actual knowledge.
2. The investigation was flawed due to the investigator's lack of subject-matter expertise and subjective bias.
3. The penalty of revocation is disproportionate and an unreasonable departure from established jurisprudence.
4. The costs award is punitive and fails to account for the Law Society's internal administrative inefficiencies.

4For the reasons that follow, the appeal is dismissed.

FACTS

5In 2019, BD, who owned an investment property in Woodstock (the Woodstock Property), decided to purchase another real estate property as an investment in Dundalk (the Dundalk Property). BD worked with a mortgage broker, Rohit Kumar (the Broker) and a realtor, Judith Dawkins (the Realtor). The Broker told BD he was pre-approved for a mortgage of $500,000 with only 5% needed as a deposit. BD had funds for the 5% deposit.

6The Broker recommended BD retain Mr. Mann as lawyer for the purchase of the Dundalk Property. After BD signed the agreement of purchase and sale (APS), the Broker told BD that a deposit of 20% of the purchase price was required, not the 5% that they had earlier advised and that BD had planned for. BD therefore required secondary financing to make up the balance of the deposit required by the primary lender. The Broker told BD the secondary financing should be in the form of second mortgages, one on the Woodstock Property, and one on the Dundalk Property. The Dundalk purchase was to close on December 2, 2019.

7The Broker referred BD to the appellant to act on the secondary financing. The appellant and Mr. Mann said the appellant was retained by BD to act on the sale of the Woodstock Property to fund the purchase of the Dundalk Property. The appellant claimed second mortgages were a fallback in the event the Woodstock Property was not sold. However, BD testified he never intended to take steps to sell the Woodstock Property in 2019, that he did not take any such steps, and that he never discussed such a possibility with the Broker or with the appellant. Text messages between BD and the Broker include no mention of selling the Woodstock Property.

8The appellant testified that an APS for the Woodstock Property was delivered to his office on Nov 21, 2019, though he could not say by whom. BD testified they did not execute the purported APS and did not know the purported purchaser. No steps were taken by the appellant or his office towards completing the sale contemplated in the APS.

9The appellant travelled to India on November 24, 2019, due to a family emergency. The documents relating to BD’s real estate and mortgage matters with Mr. Mann and the appellant were signed on November 28 or 29, when the appellant was in India. BD testified he did not meet the appellant before he left for India.

10The hearing panel observed many red flags regarding the purported APS, notably in relation to the timing: it is dated November 8, almost two weeks before it was allegedly delivered to the appellant’s office, but, by its terms, a deposit of $10,000 was payable to the appellant’s firm in trust within 24 hours, weeks before BD was even referred to the appellant. The appellant testified that neither the purported buyer of the Woodstock Property nor anyone acting on their behalf ever contacted the appellant about the alleged transaction. He testified that he never received the $10,000 deposit provided for in the APS. There was no evidence, not even from the appellant himself, that the appellant ever made any inquiries regarding the missing deposit.

11On November 28 or 29, BD attended at the office location of the appellant and Mr. Mann, to execute documents relating to the real estate purchase and mortgages. BD testified that he relied on the Broker and the lawyers and their staff “to explain the important parts to me” related to the transaction, and that he relied on the Broker and the two lawyers – Mr. Mann and the appellant – to have prepared the documents properly. BD acknowledged in hindsight the documents contained incorrect information, including inaccuracies material to the mortgage commitment from the lender for the first mortgage on the Dundalk Property. For example, in the statutory declaration regarding the Dundalk Property, BD declared that it “will be our own principal place of residence”, that “it will not be rented out”, and that “there will be no secondary financing registered on the [Dundalk] property”. All three statements were false.

12The appellant was in India when BD attended at the appellant and Mr. Mann’s offices on November 28 or 29. The appellant testified to having remotely witnessed BD signing documents via a WhatsApp call. The testimony of all other witnesses, including BD, the appellant’s spouse who did some work at the firm, and the appellant’s assistant, contradicted the appellant’s testimony. None of them confirmed that the appellant remotely witnessed the document signing or that there was even a WhatsApp call happening at that time.

13Regarding the purported closing of the sale of the Woodstock Property on December 2, 2019, the appellant claims to have prepared only the few specific documents that the first lender on the Dundalk Property required as confirmation that the Woodstock Property had been sold, as a condition of its mortgage commitment. The appellant claimed he was unaware how such documents reached Mr. Mann or the lender.

14On December 2, 2019, the appellant’s office received the second mortgage funds from the Broker. Because the appellant had not yet returned from India, Mr. Mann obtained two bank drafts from the appellant’s firm, acting on the appellant’s request to assist while he was away. He transferred the funds in trust to Mr. Mann’s firm for the purchase of the Dundalk Property. Each draft represented the net proceeds of each of the new second mortgages. The appellant testified that he did not have any conversation about the drafts with Mr. Mann, other than to tell him that this was pursuant to his client’s instructions. The appellant testified that he did not tell Mr. Mann, and that Mr. Mann did not ask, what the bank drafts were for, despite the fact that that they were to be made payable to Mr. Mann’s firm. They also purportedly did not discuss other aspects of their work for BD until a collateral matter arose after the closing. The purchase of the Dundalk Property was completed on December 3, 2019.

15By December 4, 2019, the appellant had returned to Canada. He registered a second mortgage on title for the Woodstock Property; subsequently, he registered a second mortgage on the Dundalk Property as well.

16In the Law Society’s investigation, the appellant produced notes which he claimed captured contemporaneously his work on the matters for BD. However, the hearing panel found that notes were inconsistent with other extrinsic evidence, and inconsistent with the appellant’s own account of what occurred.

DECISION OF THE HEARING PANEL

Professional misconduct

17The hearing panel began its analysis by examining the credibility of the two lawyers, stating that their testimony was often “combative” or “evasive”. They did not answer questions about their actions on this transaction directly. Rather, they stated what their practices were in general. The hearing panel found their evidence to be inconsistent with previous statements and, more importantly, to be inconsistent with the objective facts surrounding the transactions in question.

18Specifically, the hearing panel found the following evidence to be not credible, as it relates to the appellant:

• That two lawyers sharing a common reception and boardroom, one of whom granted signing authority over his trust account to the other, would not communicate with each other, at all, about transactions that not only involved the same client, but were in fact interdependent.
• Neither lawyer questioned the fact that the Broker advised the client to retain two different lawyers, who nevertheless share the same office address, to act on the two different aspects of the transactions, which were both to close on the same date.
• That it was merely a coincidence that the only three documents ever produced by the appellant’s firm for the Woodstock Property sale transaction happened to be the three documents evidencing the sale of the Woodstock property that were required by the lender advancing funds on the first mortgage on the Dundalk Property.
• That there would be no email, letter, or text messages between the appellant and BD regarding the Woodstock Property sale, either prior to the scheduled closing or after the sale was aborted. If the appellant had believed the sale transaction to be genuine, there would have been communications prior to the closing date, including about the fact that the deposit was not received, that no requisition letter was received, and that no lawyer had contacted the appellant’s firm on behalf of the purchaser. After the aborted closing date, there would have been a reporting letter and account, and there would have been communications regarding BD’s potential remedies against the purported purchaser. None of those communications were produced.

19The hearing panel noted other red flags including the following which confirmed the fact that the APS was not genuine:

• The anomalies contained in the purported APS for the Woodstock Property would have alerted the appellant to its fraudulent nature.
• The fact that no deposit was received and that no one contacted the appellant on behalf of the alleged purchaser.

20The hearing panel found, on a balance of probabilities, that the appellant knew that the Woodstock Property APS was not a genuine document, and he knew that there was no genuine sale transaction.

21With respect to whether mortgage fraud occurred, the hearing panel noted that, while the lender did not suffer any financial losses, this did not mean there was no fraud. The dishonesty of fraud could be proven by showing the parties misrepresented the true terms of the deal to the lender in securing the mortgage loan.

22In this case, there was no doubt that the lender was deprived of knowledge of material features and the true nature of the Dundalk first mortgage transaction –the fact that the Woodstock Property had not been sold, that secondary financing was placed on both properties, and that the Dundalk Property was not going to be BD’s principal residence but was an investment property – were all facts which materially increased the lender’s risk of loss. The hearing panel found that mortgage fraud had been established.

23The hearing panel also found that the appellant knowingly assisted fraud by assisting in obtaining first mortgage funding from the lender for the purchase of the Dundalk Property on the basis of false information, including the false information noted in para 22, and the false statutory declaration.

24Finally, the hearing panel found that the appellant improperly commissioned the documentation for the second mortgages on November 29, 2019, and therefore acted without integrity. The appellant’s signature in the jurat of BD’s statutory declarations was followed by the typed word “remotely”. However, as the hearing panel noted, the term “remotely” for commissioning affidavits and statutory declarations only became common usage during the pandemic, starting in 2020.

25Furthermore, the appellant’s evidence that he commissioned these documents remotely contradicted other witnesses’ evidence – no one was aware of the appellant being present remotely during BD’s meeting with the appellant’s assistant when the documents were signed.

Penalty

26Given the findings of mortgage fraud, the hearing panel confirmed that the presumptive penalty of licence revocation applied. It did not find that the appellant had satisfied the test for exceptional circumstances, and therefore the presumption had not been displaced. The hearing panel ordered the immediate revocation of the appellant’s licence.

Costs

27The hearing panel ordered the appellant to pay the Law Society the $26,000 in costs it was seeking. This represented a reduction from the Law Society’s bill of costs of $38,882 to account for changes in counsel and some possible efficiencies from joining the applications against the two lawyers together.

28The appellant argued that he had originally agreed to an agreed statement of facts (ASF) and that this should have resulted in a further discount in costs ordered. However, no ASF was ever entered as evidence. While the appellant argued that he had experienced a reduction in income due to the proceedings against him, this was not quantified, nor was there any supporting documentation for that submission.

29The hearing panel found that the costs sought by the Law Society were reasonable for a four-day hearing and that they were in line with the reasonable expectations of the parties.

ISSUES

30The appellant raises the following grounds of appeal:

• The hearing panel erred in law and in fact by finding “knowing assistance” without proof of actual knowledge.
• The investigation was flawed due to the investigator's lack of subject-matter expertise and subjective bias.
• The penalty of revocation was disproportionate and an unreasonable departure from established jurisprudence.
• The costs award was punitive or otherwise unreasonable.

STANDARD OF REVIEW ON APPEAL

31The standard of review is well established as follows:

a. correctness on questions of law,

b. palpable and overriding error on questions of fact and questions of mixed fact and law where the legal principle is not readily extricable.²

32As explained in Khan v Law Society of Ontario, “palpable” means “clear to the mind or plain to see”, and “overriding” means “determinative”, in that it “affected the result.”³

33The standard of review applicable to penalty appeals is an error in principle or a clearly unfit penalty.⁴

34As to procedural fairness, the question is whether the decision-making procedure was fair having regard to all the circumstances.⁵

POSITION OF THE PARTIES AND ANALYSIS

Knowing Assistance

Appellant’s submissions

35The appellant submits that the hearing panel failed to apply the “clear and cogent evidence” test required for serious allegations of fraud.

36The appellant’s argument is that the hearing panel did not have evidence that was sufficiently clear, convincing and cogent to satisfy the balance of probabilities test. That is, was the evidence such that the hearing panel could conclude that it was more likely than not that the appellant had knowingly assisted in mortgage fraud?

37He argues that he was a “dupe” of his client but was not a “knowing participant” and that the hearing panel failed to distinguish the two.

38He submits that the evidence suggests that his draft documents were “exploited” by either the Broker or BD to secure a first mortgage from the lender. He states that there is no proof or evidence that documents such as the trust ledger were ever provided to the lender by his office. He states that the hearing panel inferred a binding representation based on a trust ledger marked “draft” when a transaction is only finalized on a final trust ledger.

39Finally, the appellant submits that the hearing panel erred in relying on the evidence of BD, whose credibility was “questionable” since he had perpetrated the mortgage fraud, and whose testimony regarding his intent to sell was “inconsistent”.

Law Society’s submissions

40The Law Society submits that the standard the hearing panel was required to apply was proof on a balance of probabilities. There is no heightened standard of “clear and cogent evidence”. The Supreme Court in FH v McDougall⁶ made clear that the civil standard of proof is the balance of probabilities standard. It stated that “evidence must always be sufficiently clear, convincing and cogent to satisfy the balance of probabilities test.”⁷ The Law Society points out that the Appeal Division has rejected the argument that the standard of proof changes to match a case-specific definition of fraud. It further submits that the hearing panel properly and expressly applied the balance of probabilities standard.

41With respect to the finding that the appellant knowingly assisted in mortgage fraud, the Law Society submits that the hearing panel understood the law regarding fraud and knowing participation and committed no error.

42The Law Society states that when faced with irregularities which may be material, licensees are required to make appropriate inquiries to determine whether they may be facilitating a fraud. The repeated failure to make adequate inquiries, coupled with continuing to act in the face of inadequate responses, may support the conclusion that the lawyer knows or suspects that the transactions in question are not, or may not be, genuine.

43In this case, the hearing panel understood that subjective knowledge includes actual knowledge and also imputed knowledge: willful blindness or recklessness. It made findings on a balance of probabilities regarding the appellant’s knowledge based on the documents that were produced and provided to the lender which contained untrue or misleading information.

44With respect to the findings of credibility, the Law Society submits that these are owed deference on appeal. The hearing panel made multiple adverse determinations of credibility of the appellant, which were material to its determination of the facts. On the other hand, the Law Society argues, BD’s credibility was not central to the hearing panel’s decision. Whether BD had any awareness of the fraud or contradicted himself at times did not prevent the hearing panel from assessing the appellant’s level of knowledge and participation in the fraud.

45Likewise, the Law Society argues, the hearing panel was not required to conclusively determine who was the directing mind behind the fraud or whether the Broker or BD had any role to play in it. It was also not necessary for the hearing panel to put all the puzzle pieces of the fraud together, such as who provided documents from the appellant’s office to Mr. Mann’s office or to the lender. The hearing panel had enough of the puzzle pieces put together to conclude that the appellant was not credible in significant ways and that the facts supported a determination that he knowingly assisted in a fraud.

Analysis

46The hearing panel’s reasons make clear that it applied the correct civil standard of a balance of probabilities. The reasons repeat this standard explicitly at paras 117, 120, 121, 122, 129, and 130. The hearing panel was required to apply that standard based on evidence that was “sufficiently clear, convincing and cogent … [to satisfy] the balance of probabilities test.”⁸

47In this case, the hearing panel did not have direct evidence that the appellant knowingly assisted mortgage fraud. There was no admission by the appellant and no “smoking gun” document. However, as noted in Law Society of Upper Canada v Nguyen, “Circumstantial evidence may lead to an inference, on a balance of probabilities, that a transaction was fraudulent.”⁹ Indeed, “the accumulation of questionable, suspicious and unexplained circumstances – recognizable red flags – supports findings of fraud.”¹⁰ Therefore, it was not necessary for the hearing panel to have direct evidence to make the findings it did.

48Furthermore, some red flags also invite concern about the lawyer’s knowing involvement in dishonesty or fraud, including failing to inquire about circumstances which the licensee is aware of that require further inquiry, and failing to disclose some or all red flags to the lender.¹¹ As noted in Nguyen, repeated failure to disclose recognized red flags to a lender or to make adequate inquiries about such red flags may support the conclusion that a lawyer knows or suspects that the transactions in question are not or may not be genuine.¹² It is often the case that knowledge in mortgage fraud cases is established based on circumstantial evidence.

49In our view, there is no palpable and overriding error in the hearing panel’s finding that the appellant knowingly engaged in mortgage fraud. The hearing panel made findings of fact on a balance of probabilities regarding the appellant’s knowledge based on the documents that were produced and provided to the lender which contained untrue and misleading information. There was sufficient evidence of irregularities, red flags and concerning features of these transactions such that the appellant ought to have made further inquiries. The fact that he did not supports the inference that he knew that the transactions were fraudulent, whether by actual knowledge, wilful blindness or recklessness.¹³

50The appellant has not pointed to any palpable and overriding error of fact in the hearing panel’s assessment of the evidence.

51None of the factual issues raised by the appellant are incompatible with the hearing panel’s findings and so they do not disclose a palpable and overriding error. It may well be that draft documents were in fact exploited by either the Broker or BD to secure a mortgage from the lender. Whether or not the Broker or BD were in on the scheme does not change the nature of the appellant’s own participation or the hearing panel’s assessment that he knowingly assisted in mortgage fraud.

52Whether the panel referred to a document that was in draft form and whether there was evidence that documents such as the trust ledger were provided to the lender by the appellant’s office are not material facts. While such evidence would have been an even stronger indication that the appellant knowingly assisted mortgage fraud, none of these details – individually or collectively – were necessary for the hearing panel’s conclusion. These are not palpable or overriding errors.

53At paras 108-116 of the hearing panel’s reasons, the panel outlines all of the elements from the appellant’s and Mr. Mann’s evidence that the panel found not credible. That the appellant’s story is so incompatible with the documentation, with other witnesses’ testimony, and with common sense is itself a strong indicator of deception and of knowing participation in the scheme.

54The appellant argues that he may have been a dupe and that this is incompatible with being a knowing participant. The appellant has not pointed us to any evidence – let alone clear and cogent evidence to meet the balance of probabilities standard – to establish that he was a dupe. Indeed, the evidence suggests that he was not a dupe because there were clear red flags on the face of the documents and in the features of the transactions that would have immediately alerted him to the fraud. The hearing panel was equally not persuaded that he was a dupe because it found, based on the evidence before it, that the appellant was a knowing participant. The appellant has not pointed to any palpable and overriding error in the hearing panel’s assessment of the evidence or in its finding of knowing participation.

55The appellant takes issue with the hearing panel’s reliance on BD’s testimony. A panel’s assessment of credibility is owed deference and requires a palpable and overriding error to overturn. As noted, the hearing panel was entitled to make the findings of credibility against the appellant based on the documentary evidence, the testimony of other witnesses, and on common sense.

56With respect to BD, the hearing panel did not make any findings of credibility per se. This is because it did not need to rely on BD’s credibility in order to make the findings it did. Whether BD intended to sell the Woodstock Property and whether his evidence was inconsistent on that point did not change the core finding of the panel – that the appellant knowingly assisted in mortgage fraud.

57This ground of appeal is dismissed.

Flawed investigation

Appellant’s submissions

58The appellant argues that the Law Society investigator did not consider whether the appellant may have been a dupe and instead prematurely concluded that he must have facilitated a fraud. He argues that the Law Society investigator focused her investigation on corroborating BD’s story.

59The appellant also submits that the Law Society investigator lacked subject-matter expertise in real estate transactions and instead relied on a colleague. He argues that this lack of expertise impacted the investigation and its outcome.

60Finally, the appellant submits that the Law Society’s investigator “used subjective and critical language in her testimony” when observing that the encrypted communications application WhatsApp was not commonly encountered as a usual tool in lawyers’ practices and was used by criminals.

Law Society’s submissions

61The Law Society submits that the appellant has not linked any of the purported problems in the investigation with any alleged errors made by the hearing panel. The hearing panel reached its own conclusion based on the evidence and so any alleged errors in the investigation were remedied by the hearing evidence. It was the hearing panel, not the investigator, which made findings of misconduct.

62The Law Society argues that its investigator was not presented as an expert witness. Whether the investigator sought out the assistance of knowledgeable colleagues is not problematic, but rather commendable.

63The Law Society further submits that the investigator’s observations about WhatsApp were not challenged by any other evidence, and there was no indication this was testimony the hearing panel considered material.

Analysis

64We are not satisfied that the investigation was flawed as is alleged. In any event, none of the purported issues raised by the appellant regarding the Law Society’s investigation materially affects any of the findings of the hearing panel. As previously stated, there was sufficient evidence before the hearing panel to make the finding that the appellant knowingly assisted mortgage fraud.

65This ground of appeal is dismissed.

Penalty

Appellant’s submissions

66The appellant submits that the penalty the panel imposed, revocation, is disproportionate to the misconduct the panel found. He submits that the panel failed to weigh the appellant’s submission that he was a “simple dupe”, which should have been a significant mitigating factor.

67The appellant argues that the panel failed to weigh mitigating factors such as a lack of discipline history, his co-operation with the Law Society’s investigation and the fact that he did not benefit directly from the fraudulent transactions and only considered the character letters.

Law Society’s submissions

68The Law Society submits that, based on the findings of misconduct actually made by the hearing panel against the appellant, revocation was the appropriate penalty based on the principle of presumptive revocation.

69Presumptive revocation can only be displaced by exceptional circumstances. In this case, the Law Society argues, the mitigating factors asserted by the appellant did not amount to exceptional circumstances. The hearing panel heard the appellant’s submissions with respect to mitigation but it was not required to explore them in detail in the reasons since these factors were not material to its decision, as they were not evidence of exceptional circumstances.

Analysis

70As noted above, the standard of review applicable to penalty appeals is an error in principle or a clearly unfit penalty.

71It is well-established in Tribunal jurisprudence that the presumptive penalty for knowingly assisting in mortgage fraud is revocation, and this penalty can be avoided only in exceptional circumstances.¹⁴ Having found that there was no error in the hearing panel’s determination that the appellant knowingly assisted in mortgage fraud, it follows that (absent exceptional circumstances) presumptive revocation was the appropriate penalty. It was not disproportionate to the misconduct the hearing panel found; in the circumstances, it was the only appropriate penalty.

72The appellant has put forward what he says are mitigating factors. When presumptive revocation applies, mitigating factors are not weighed or considered. The only consideration is exceptional circumstances, as that term has been defined in the jurisprudence. These may include factors such as medical reasons, financial desperation or situations of duress.¹⁵ Generally, they should provide an explanation for, and be causally connected to, the licensee’s misconduct such that it would be obvious to other members of the profession, and to the public, that the underlying circumstances of the individual clearly obviate the need to provide them reassurance of the integrity of the profession.¹⁶

73The panel found that the test for exceptional circumstances was not met. Indeed, the appellant does not argue that there are exceptional circumstances, only mitigating factors. While these factors may be relevant on a reinstatement application, none of these factors rise to the level of an exceptional circumstance, and the hearing panel did not err in finding that none had been established.

74The hearing panel made no error in principle. Revocation was not an unfit penalty. Rather, it was the only reasonable penalty available, absent exceptional circumstances, of which there were none.

75This ground of appeal is dismissed.

Costs appeal

Appellant’s submissions

76The appellant submits that the $26,000 costs order is punitive rather than compensatory. He further argues that the Law Society's costs were unnecessarily inflated by replacing lead counsel twice, requiring the appellant to pay for the "learning curve" of new staff.

Law Society’s submissions

77The Law Society submits that the hearing panel’s determination of costs is discretionary and is owed deference. It states that the Law Society’s actual costs incurred were $39,000 but the hearing panel ordered the reduced amount sought by the Law Society of $26,000. Therefore, any duplication of work by discipline counsel was taken into account.

78The Law Society argues there is no basis for the suggestion that the hearing panel viewed the costs order as a way to punish the appellant. In any event, the hearing panel took the appellant’s arguments regarding costs into account in exercising its discretion and the appellant has not identified any basis on which to set aside the costs award.

Analysis

79Costs decisions are, by their nature, discretionary and fact-dependent. A costs order should not be disturbed if the panel weighed the proper factors in reaching its conclusion¹⁷ and the costs fall within the range of reasonableness.

80In this case, the appellant has not pointed to any error by the hearing panel in assessing costs.

81The hearing panel considered the arguments made by the appellant on costs. It found that the reduced costs were reasonable for a four-day hearing and consistent with the expectations of the parties. At para 143, the hearing panel explicitly acknowledged the duplication of work which led to a lower costs award.

82There is no basis to disturb the hearing panel’s costs award. This ground of appeal is dismissed.

CONCLUSION

83The appeal is dismissed.

84If the parties cannot agree on costs, the Law Society may file written submissions of no more than four single-spaced pages, apart from a bill of costs and any authorities, within 14 days of the date of these reasons.

85Any responding submissions should also be in writing, no more than four single-spaced pages in length, and any authorities and be filed within 28 days of the date of these reasons.

Footnotes

1. 1Law Society of Ontario v Sood and Mann, 2025 ONLSTH 152.
2. 2Law Society of Ontario v Manilla, 2021 ONLSTA 25 at para 10.
3. 32022 ONSC 1951 at para 73.
4. 4Law Society of Ontario v Watson, 2025 ONLSTA 7 at para 38.
5. 5Afolabi v. Law Society of Ontario, 2025 ONCA 257 at para 60.
6. 62008 SCC 53.
7. 7At para 46.
8. 8McDougall at para 46.
9. 92018 ONLSTH 45 at para 45.
10. 10Nguyen at para 47.
11. 11Nguyen at para 55, quoting Law Society of Upper Canada v Yungwirth, 2013 ONLSAP 24.
12. 12Nguyen at para 56.
13. 13Nguyen at para 51.
14. 14Law Society of Ontario v Nguyen, 2020 ONLSTA 10 at para 53.
15. 15Bishop v Law Society of Upper Canada, 2014 ONSC 5057 (Div. Ct.) at para 31.
16. 16Bishop at para 31.
17. 17Law Society of Ontario v Bahimanga, 2019 ONLSTA 25 at para 109.