LAW SOCIETY TRIBUNAL

HEARING DIVISION

Date: February 3, 2026

Tribunal File No.: 24H-131

BETWEEN:

Nizam-u-din Sajid Qureshi

Applicant

• and -

Law Society of Ontario

Respondent

Before: Murray Walter Chitra (chair), Suzanne Clément, Murray Klippenstein

Heard: November 4-6, 2025, by videoconference

Appearances:

Applicant, self-represented

Bernadette Saad, for the respondent

Summary:

QURESHI – Licensing – Retroactive Revocation – The Lawyer applied for licensing in 2019 – He has been practising criminal and entertainment law since 2021 – The Lawyer was found to have deliberately made false or misleading statements in his licensing application – His application for licensing was dismissed and his licence was retroactively revoked.

REASONS FOR DECISION ON LICENSING

1Murray Walter Chitra (for the panel):– Section 27(2) of the Law Society Act, RSO 1990, c L.8 (the Act), requires that applicants for a licence to practise law must be of good character. When that is in question, the Law Society may refer the matter to a hearing.

2On November 26, 2019, Nizam-u-din Qureshi applied to the Law Society for a licence to practise law. In his application he affirmed that he had never been found guilty or convicted of any offence under statute in Canada or elsewhere and had never been sanctioned by any court or tribunal.

3Mr. Qureshi was granted a licence July 21, 2021. Since then, he has worked as a lawyer in the areas of criminal and entertainment law.

4It subsequently came to the attention of the Law Society that Mr. Qureshi was convicted in Michigan following a lengthy criminal process from 2012 to 2017. This conviction was for the felony offence of seduction of his stepdaughter in 2011, when she was 11 or 12 years old.

5On November 14, 2024, the Law Society referred the matter of Mr. Qureshi’s licence for a hearing. The questions before us are:

1. Did Mr. Qureshi deliberately make false or misleading representations or declarations in his 2019 application by way of either commission or omission? If so, he is deemed by s 8(2) of By-Law 4 not to be of good character, and his license is retroactively revoked.

2. If his representations were not deliberately false or misleading, is Mr. Qureshi currently of good character as required by s 27(2) of the Act? The onus rests with him.

6We received evidence on the factual history of these matters between November 4-6, 2025. We requested and subsequently received written submissions from the parties on the two questions set out above.

7For the following reasons, we find that Mr. Qureshi deliberately made false or misleading statements in his application for a licence knowing that they were false or misleading. And even if we did not so find, he was reckless or willfully blind with respect to their truth. His application is dismissed. We need not address the second question.

BACKGROUND

8Mr. Qureshi grew up in Toronto. He says that he wanted to be a lawyer since he was 12 or 13. This was because his grandfather was a much-respected lawyer in Pakistan. He wished to be just like him.

9As an adult he worked a number of different jobs. This included employment as an events co-ordinator, DJ, salesman, substitute teacher, fundraiser, producer and working on music, TV, radio, film and writing projects.

10Mr. Qureshi began his legal studies in the United States in 2005 at the College of Law at Michigan State University. He graduated with a law degree in 2008.

11His plan was to practise entertainment law in California. However, between 2008 and 2012, he failed the California bar exams three times. He worked in sales and as a teacher.

Marriage

12In 2007, while in law school, Mr. Qureshi married a woman with two young daughters. That was after they had lived together for a year.

13Mr. Qureshi says that almost from the start, their marriage was marked by tension and verbal abuse by his wife. His wife was “vicious” and “malicious”. She did not “step up” as a parent. They fundamentally disagreed about matters relating to the structure of the children’s lives, such as schedule, bedtime, and discipline. This “ramped up” after his graduation.

14He states that despite this, he developed a strong bond and loving relationship with his two stepdaughters, who were 5 and 9 at the time of his marriage to their mother. This was “very healthy”, in contrast to the ongoing tension in the home caused by his wife.

15Mr. Qureshi’s evidence was that this was further complicated by jealousy between the sisters and their mother, and difficult relationships with his wife’s ex-spouses. He blames the turmoil and distractions in his household as the main reason why he was not able to pass the California bar exams.

16Mr. Qureshi says that his younger stepdaughter felt left out when her older sister went to visit her biological father. She had “serious father issues”. He attempted to compensate by taking her on what he described as “special” activities. This included ice skating and going to the mall.

17Mr. Qureshi testified that his younger stepdaughter was very affectionate towards him. She called him “daddy” and would often sit on his lap. During a trip to Toronto in August 2012, it was necessary for him to speak to her about appropriate boundaries. She then felt “spurned” and “rejected”.

18When they returned to Michigan, two days before the start of school, there was a major argument between him and the two girls about sleep routines. This woke his wife. The next morning, when he awoke, she and the two girls were gone from the family home.

Sexual assault allegations

19Shortly after, the younger daughter made allegations to her mother that she had been sexually assaulted by Mr. Qureshi. He states that these allegations were totally false. He believes this was done at instigation of his older stepdaughter.

20Mr. Qureshi’s wife went to the police. In his opinion she did so to destroy his reputation, have him deported, and avoid immigration sponsor support obligations.

21With the financial support of his parents, he hired a local lawyer who was a former judge. Mr. Qureshi testified that he co-operated with the police. However, on the advice of his lawyer, he refused to take a police polygraph. Instead, he paid for an independent one and “passed”. The police did not accept those results.

22The investigation appeared to come to a standstill, and Mr. Qureshi decided to return to Toronto and live with his parents as their caregiver.

23In June 2013 he was asked to be the best man at a wedding in Minneapolis. He contacted his Michigan lawyer to “proactively” confirm that there were not outstanding warrants that might complicate such a trip. Mr. Qureshi states that he believes that his lawyer spoke directly to the police who reached out to his ex-wife who pressed for charges to be laid.

24Criminal charges were brought against him in July 2013.They consisted of four counts of second-degree sexual assault against a person under the age of 13, that person being his younger stepdaughter. The abuse was alleged to have taken place between 2007 and 2012.

25Mr. Qureshi returned to Michigan and turned himself in.

Trial, incarceration, and appeal

26A trial before judge and jury took place in 2014. Mr. Qureshi’s two stepdaughters and wife testified. He believes that they had been coached. Mr. Qureshi and his mother gave evidence.

27Mr. Qureshi states that he was initially confident because he believed there was sufficient evidence to exonerate him. However, he says his trial lawyer did not use that information to impeach prosecution witnesses or explore inconsistencies in their evidence. Critical defence strategies were abandoned by his lawyer without explanation. This resulted in what he describes as a “collapse of trust”.

28In July 2014, Mr. Qureshi was convicted of three of the four counts. He was immediately taken into custody. The following month he was sentenced to four-and-a-half to fifteen years’ imprisonment. He described this as “soul-shattering”.

29Mr. Qureshi retained a new lawyer with the continuing financial support of his parents for an appeal. He described this lawyer as being very expensive. Mr. Qureshi spent as much time as possible in his prison’s law library looking for cases to support that appeal. He wrote a book and screenplay.

30On January 5, 2016, his appeal was granted based on ineffective assistance of counsel. This was for failure to object to inadmissible corroborating evidence. A new trial was ordered. Mr. Qureshi felt vindicated.

31The prosecution sought leave to appeal to the Michigan Supreme Court. On May 24, 2016, it was denied.

32Six weeks later, after almost two years in custody, Mr. Qureshi was released on bail pending his new trial. He was required to wear an ankle bracelet because of concerns that he could be a flight risk. He started working in prisoner rights advocacy.

Plea deal, second trial, and conviction

33Mr. Qureshi states that his lawyer provided the new prosecutor with evidence he had gathered and the results of his legal research. He says that the prosecutor did not actually believe there was a need to pursue the outstanding charges. However, because of pressure from his wife, a new trial was scheduled.

34By this point, his parents were overextended by the costs of the trial and appeal. To avoid further expense and an emotional ordeal he agreed to a “no contest” plea arrangement. It was signed February 23, 2017, and read:

1. Plea to Seduction

Mr. Qureshi is pleading no contest to one count of seduction … Pursuant to People v. Killebrew, Mr. Qureshi will not be sentenced to any term of incarceration.¹

2. The Offence of Seduction

The offense of seduction requires that a man seduce and debauch an unmarried woman.

3. Factual Basis

In 2011, Mr. Qureshi seduced and debauched an unmarried, chaste woman in Meridian Township, Ingham County, Michigan. Mr. Qureshi persuaded through promise an unmarried woman to engage in intemperate behaviour.

4. Consequences

Mr. Qureshi understands the possible immigration consequences of this plea, and he has consulted with immigration attorneys about this matter.

Mr. Qureshi will not have to register on the Sex Offender Registry.

Mr. Qureshi understands that there are other collateral consequences, such as not being allowed to possess a firearm, that occur because of this conviction.

5. Dismissal of Other Counts

Upon Mr. Qureshi’s successful plea and sentence to an added count of seduction, the Ingham County Prosecutor’s Office moves to dismiss all other counts.

35The plea agreement contains acknowledgments signed by Mr. Qureshi and his lawyer. Mr. Qureshi’s states:

I have read this agreement and carefully discussed every part of it with my attorney. I understand the terms of this agreement, and I voluntarily agree to those terms. My attorney has advised me of my rights, of possible defenses, of the sentencing provisions, and of the consequences of entering into this agreement. No promises or inducements have been made to me other than those contained in this agreement. No one has threatened or forced me in any way to enter into this agreement.

36Mr. Qureshi was required to sign an “advice of rights” form. It explained in detail the consequences of his plea and that the court must be convinced he understood these before it would be accepted. It concluded by stating, “If your plea is accepted, any appeal from your conviction and sentence pursuant to this plea will be by application for leave to appeal and not by right.”

37The plea was tabled with the court the day it was signed. As part of the plea process, the prosecutor identified for the record the person who was the victim of the alleged seduction as Mr. Qureshi’s younger stepdaughter. She would have been 11 or 12 years old at the identified time of the offence.

38A judge reviewed the proposal and questioned Mr. Qureshi as to whether he understood the nature and consequences of his plea. He confirmed that he did and wished to make it. The judge concluded by stating:

The Court finds the plea is understandingly and voluntarily made without undue influence, threats or promises of leniency. As to the findings of the Court, it is accurate as it pertains to Count 5 Seduction and the findings support that conviction and a conviction will enter on Count 5 and the plea accepted. Sentencing date is?

39Sentencing took place April 5, 2017. Mr. Qureshi was present. The judge started off by saying: “This is People of the State of Michigan versus Nizam Qureshi …And this is the time set for sentencing. Mr. Qureshi, you were convicted of seduction, a felony punishable by up to 5 years in prison.”

40The parties then discussed a pre-sentence report prepared for the occasion. Mr. Qureshi’s wife gave a brief statement on behalf of her youngest daughter:

… I know now why people chose to stay quiet. This process has been painful, long and all for not. I take solace in knowing he will have to answer to God for it. I would ask that he be deported, so that my girls do not have to look over their shoulders anymore.

41The judge then noted that “considering the history of this case” she was prepared to go along with the negotiated plea agreement. Speaking directly to Mr. Qureshi, she stated:

I am sentencing you to zero days in jail with zero credit and you do have to pay $130 to the Crime Victims fund and $68 in state costs. Costs to the county in the amount of $250, a huge reduction from the State Court Administrative Office calculated costs for criminal case in Ingham County. I see your puzzlement, they’re payable upon conviction. It doesn’t matter what happens with the conviction.

42Mr. Qureshi returned to Toronto that same day.

Application

43Mr. Qureshi subsequently studied for, wrote and passed the National Committee of Accreditation exams. On November 26, 2019, he submitted a licensing application to the Law Society of Ontario. He swore/affirmed in that application that the contents of it were true.

44One part of the application concerned character. It contained a series of mandatory questions that all applicants must answer. Candidates were advised that the questions “pertain to matters arising in any jurisdiction in Canada or in any other country”.

45Questions 1 and 13 of the character section of the application are central to this hearing. They asked:

1. Have you ever been found guilty of, or been convicted of, any offence under any statute?

Please exclude:

i) speeding and parking tickets;

ii) offences for which more than one year has passed since you were discharged absolutely or more than three years have passed since you were discharged on conditions prescribed in a prohibition order; and

iii) convictions or findings of guilt under the Controlled Drugs and Substances Act for possession of cannabis not exceeding 30 grams or cannabis resin not exceeding 1 gram that did not include a term of incarceration.

(If you have been found guilty or been convicted of an offence under the Young Offenders Act or the Youth Criminal Justice Act or if you have received a pardon or a record suspension with respect to any offence, please refer to the Good Character section of the ‘Completing the Lawyer Licensing Process Application’ online guide for further details.) …

13. Have you ever been sanctioned or had a penalty imposed upon you by a court, an administrative tribunal or a regulatory body? If yes, please provide details.

46Mr. Qureshi answered “no” to both questions 1 and 13. He declared under oath that this information was “current, complete and correct” and agreed “to file additional information as soon as possible should the response to any question change prior to the date of my call to the Bar of Ontario.”

47Mr. Qureshi went on to study for and passed his Ontario bar exam in March 2020. He completed an articling term with a busy criminal law firm in Windsor. As was noted earlier, he was granted a licence to practise law July 21, 2021.

Investigation

48Ultimately, Mr. Qureshi’s conviction, sentencing and sanctions in Michigan came to the attention of the Law Society, and he was asked to account for his failure to admit those facts and provide details of what had happened on his application for licensing.

49He made written representations on April 7 and July 14, 2023, and he was interviewed on August 21, 2023. He also spoke to this in his evidence at this hearing. A number of explanations were offered by Mr. Qureshi.

50Mr. Qureshi stated that when he completed the application on November 26, 2019, he genuinely believed that his court dealings in Michigan were exempt from reporting. He says that he “wholeheartedly considered” they had been concluded in a “discharge on the plea agreement” rather than with a conviction.

51Mr. Qureshi pointed out that the findings in his first trial had been overturned on appeal and those allegations withdrawn at the second trial. Therefore, the initial convictions, allegations and jail sentence had been “scrubbed”, “killed”, “quashed”, “erased”, “absolutely discharged” and effectively no longer existed. To his mind, the “Michigan matter” had been “fully resolved” in a way that did not require reporting.

52He said that any confusion about the difference between a discharge and conviction on his part was understandable. He had only taken criminal law 101 at law school.

53Mr. Qureshi stated that his second plea was simply a device to bring closure after years of hardship caused by a trial process that had gone profoundly wrong. His plea was a means to end an ordeal marked by judicial error. It was a means to bring stability to his life.

54Mr. Qureshi asserted that his “no contest” plea was not an admission of wrongdoing. The charge that he had agreed not to contest was “archaic”. It had not been used for decades. He questioned whether it could be applied to his stepdaughter given that she was a “child” and not an “unmarried woman”. Further, it made no reference to “sexual” conduct. He took issue with the meaning of the term “debauch”.

55Mr. Qureshi pointed out that his plea agreement resulted in no additional jail time or probation. No penalty or sanction was imposed, apart from restrictions on firearm ownership and on his ability to vote. He did not view these as serious, relevant or requiring reporting to the Law Society.

56When questioned by us exactly why he answered “no” to question 13 and did not report such sanctions, Mr. Qureshi responded by saying that he thought everything was wiped out by his plea. Nothing hung over him. This was “absolute vindication.”

57Further, at the time, he was living with the effects of PTSD. On the day of his plea, he was extremely nervous because the judge he was appearing before was the same one who had imposed his earlier sentence of imprisonment.

58Mr. Qureshi states that he does not remember much of what was said that day. He subsequently put the whole experience in a locked box on a “shelf” in his brain, mind and heart where it remained compartmentalized collecting dust.

59As well, Mr. Qureshi pointed out that his “discharge” had occurred more than three years before his application (allowed by the exemption provisions to question 1).

60When questioned at the hearing about this timing and how he thought the period between his second sentencing (April 4, 2017) and the date of signing the application (November 26, 2019) was three years, he could not explain the discrepancy other than to say he was not counting month by month.

61On April 7, 2023, Mr. Qureshi provided the Law Society investigator with a US criminal records check under the name “Nizamudin Sajid Qureshi”. It did not show any criminal convictions. At the time, he pointed to this as proof that he did not have a criminal conviction.

62When questioned about the reliability of this record by the investigator, Mr. Qureshi then provided a second criminal record check dated April 10, 2023, under the name “Nizam S Qureshi”. It showed a criminal conviction in 2017 for seduction.

63In his evidence, Mr. Qureshi explained that in the past he had experienced difficulty with using his hyphenated name on US Government forms. He suggested that this was likely the reason for the first negative response. This was not a deliberate attempt on his part to misrepresent his criminal history.

64Mr. Qureshi was asked about his articles at a criminal law firm in Windsor. He stated that this experience provided him with a firmer understanding of criminal law principles. However, he never took that understanding and retroactively applied it to his situation.

65At no point did this experience articling or any learning garnered during his bar admission exams cause him to revisit and correct his mistaken affirmation because he considered that he was discharged rather than convicted.

ANALYSIS

66Section 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 a licence, by commission or omission, is deemed thereafter not to meet, and have not to have met, the requirements for the issuance of any licence under the Act.

67In Levenson v Law Society of Canada, 2009 ONLSHP 98, the provision was described as follows:

92In our view, s. 8(2) cannot be interpreted so as to automatically disqualify an applicant from being issued a licence when his or her application is, in some respect, inaccurate, regardless of whether the inaccuracy is inadvertent. That would be fundamentally unfair in the extreme. Not does its plain meaning compel such an interpretation.

93This subsection is designed to capture those situations in which an applicant is deliberately misleading in his or her application or in connection with it. 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 lack of good character.

68A “deliberate misrepresentation” is one known to be false or misleading, or the person making it is reckless or wilfully blind with respect to its truth. It does not matter why a misrepresentation was made. What matters is whether the misrepresentation is knowingly or recklessly made, whether with actual or constructive knowledge.² In such situations, a hearing panel cannot grant a licence.³

69The Law Society may require a licensee to apply to the Tribunal for reconsideration of their licence on the grounds that the licensee may have made a false or misleading representation or declaration when they originally applied for and was subsequently granted a licence.⁴ Cases before this Tribunal have been brought for either not reporting or misrepresenting prior criminal conduct.⁵

70When assessing whether an applicant has made a “deliberate” misrepresentation or omission in their application, a panel must consider the applicant’s explanation by examining the surrounding facts.⁶

71The credibility of such explanations should not be assessed only by examination of the demeanor of witnesses. Rather, the truth of any witness’s story must be evaluated against what a reasonable person would normally expect to happen in similar circumstances.

72The British Columbia Court of Appeal in Faryna v Chorny, 1951 CanLII 252 at p 357 described this as follows:

In short, the real truth of the story of a witness … must be in harmony with the preponderance of the probabilities which a practical and informed person would normally recognize is reasonable in that place and those conditions.

73Mr. Qureshi asserts that any inaccuracies in his 2019 licensing application were the result of “a misunderstood legal disposition and honest recollection errors, not deceit”. He always acted in good faith. He always believed the prior matters were resolved and had no reason to believe he was providing inaccurate information.

74Mr. Qureshi argued that the Law Society’s characterization of his Michigan criminal proceedings was incomplete and unfair. His actions must be seen through the realities of a collapsing marriage, conflicts over children, and household instability. He says he has never attempted to obscure or hide his past.

Conclusion

75We find, considering the evidence before us, that Mr. Qureshi’s explanations for not correctly and fully reporting his conviction and sanctions in a serious criminal matter are neither accurate nor true. They not only do not ring true, but do not reflect contemporaneous documents, affirmations, and prior evidence given under oath.

76Mr. Qureshi was the subject of a criminal investigation and multiple court proceedings in Michigan spanning over five years for serious allegations of sexual misconduct with a minor under his care. He was incarcerated for almost two years.

77This involved two criminal hearings where he was the accused, and related appeals. He conducted extensive research for these proceedings using his legal training. He was actively engaged in and present for all of these proceedings. For years this was the centre of his life.

78The record for his second trial details a negotiated plea of “no contest” by Mr. Qureshi to a criminal felony offence. This plea was carefully negotiated, prepared and reviewed. It even contains a last-minute change in writing initialed by Mr. Qureshi. It was entered into with the assistance of experienced criminal counsel and formally endorsed by the court.

79Mr. Qureshi attested in various court documents and at a formal plea proceeding that he fully understood the nature and consequences of his plea decision and the resulting disposition. He responded under oath to questions put to him by the judge at his plea hearing affirming his understanding and agreement.

80The record of the plea proceeding nowhere suggests that it was for a “discharge”. Rather, it only speaks to Mr. Qureshi being “convicted”, “sentenced” and subject to “collateral consequences”. The use of these terms is highlighted in the contemporaneous documents and transcripts reproduced in paras 34-41 above.

81There was no evidence presented to us to support assertions that the conviction that was imposed upon him on February 23, 2017, with his agreement and legal advice, was anything other than what he publicly accepted under oath and witnessed being imposed upon him at his plea proceeding.

82Mr. Qureshi then participated in a separate sentencing hearing on April 4, 2017. He was the subject of a pre-sentence report. At that hearing the judge formally “sentenced” him.⁷ This did not result in additional incarceration. However, the acknowledged collateral consequences were that Mr. Qureshi was barred from owning or possessing a firearm and from voting. He was assessed costs.

83Thirty-one months later, Mr. Qureshi filed his application for a licence to practise law in Ontario. In it, he denied that he had ever been found guilty or convicted of any offence, sanctioned or had a penalty imposed upon him by a court. This was not true.

84Mr. Qureshi’s explanation for this is he misunderstood legal terminology relating to what took place in court, suffered from PTSD, and he did not want to remember this horrible episode in his life. There is no medical evidence before us to corroborate any assertions of trauma or impairment to Mr. Qureshi’s memory or perception.

85We find it extremely improbable that Mr. Qureshi did not remember, had forgotten, or suddenly ceased to appreciate that he had recently been “convicted” or that he had been “sanctioned” for a criminal offence. There is no air of reality to such an assertion.

86Further, it strains credulity to the breaking point to suggest that he could honestly have believed that the matters described above were of no relevance to possible concerns about his character and did not require mention when petitioning for a licence to provide legal services to members of the public.

87The application form highlighted in para 45 above asked Mr. Qureshi if he had ever been found guilty or convicted of any offence under any statute. The exemptions do not exclude convictions imposed where a new trial was ordered on appeal. They do not exclude convictions imposed as part of a plea deal.

88Nor is there any exemption from reporting a sanction or penalty imposed by a court. There is no option for an applicant to decline to report consequences imposed that they view as redundant or insignificant. That is for the Law Society to assess.

89The obligation of candour and transparency required Mr. Qureshi to honestly and openly bring his criminal history to the attention of the Law Society for their review. Such matters cannot be put in a “locked box” in someone’s mind and forgotten. This is not an option.

90In this case, Mr. Qureshi did not even seek guidance from the Law Society when he filled out his application about whether or not his disclosure obligations were engaged.

91Even assuming that Mr. Qureshi believed that he had been “discharged” rather than “convicted”, his application clearly required him to report it under question 1 unless three years had passed. Only thirty-one months had. His explanation for miscalculating those dates is neither coherent, reasonable, or plausible; it has no foundation for a rational excuse for not responding to this simple question.

92We also find it telling that even after Mr. Qureshi completed his articles at a criminal law firm and gained a firmer understanding of criminal law principles, he failed to retroactively apply them to his situation and take the required steps to correct or clarify his wrong application answers.

93As well, we have concerns that the initial criminal records check provided by Mr. Qureshi to the Law Society investigator made no mention of a criminal history and he used this to argue that this confirmed his explanation that he had never been convicted.

94Collectively these untruthful answers do not reflect momentary oversights, genuine confusion, inadvertent omissions, lapses of memory, misunderstandings, honest mistakes or miscalculations. Rather, they demonstrate deliberate efforts to obscure his criminal conviction and the circumstances giving rise to them.

95He adjusted the nature of the outcome of his trial process (converting a conviction into a discharge) and timeline (turning 31 months into more than three years). His subsequent explanations are self-serving rationalizations.

96We find that Mr. Qureshi deliberately made false or misleading statements in his 2019 licensing application. He therefore is deemed by s 8(2) of By-Law 4 not to have met the requirements for issuance of that licence.

ORDER

97We order:

1. This application for licensing is dismissed. Mr. Qureshi’s licence is retroactively revoked.

2. If the Law Society seeks costs of this application, it shall deliver short written submissions by February 17, 2026, and Mr. Qureshi may respond by March 3, 2026.

Footnotes

1. 1Certain words referred to in key documents, and transcripts are highlighted. These will be referred to later in our analysis and are marked as such for clarity.
2. 2Dumanian v Law Society of Ontario, 2024 ONLSTA 7 at para 53, and Jariwala v Law Society of Ontario, 2025 ONLSTH 181 at para 98.
3. 3Law Society of Upper Canada v Stewart, 2012 ONLSAP 30 at para 32.
4. 4Amendola v Law Society of Ontario, 2023 ONSC 4123, Agbarakwe v Law Society of Ontario, 2025 ONLSTH 45 at para 1, Khan v Law Society of Upper Canada, 2012 ONLSTH 15 at para 18, and Saran v Law Society of Ontario, 2025 ONLSTH 7 at para 122.
5. 5Aujila v Law Society of Ontario, 2025 ONLSTH 10, and Jariwala, above.
6. 6Taylor v Law Society of Ontario, 2019 ONLSTH 25 at para 66.
7. 7Para 41 above.