LAW SOCIETY TRIBUNAL
HEARING DIVISION
Date: February 10, 2026
Tribunal File No.: 25H-103
BETWEEN:
Law Society of Ontario
Applicant
- and -
Md Ishtiaque Ahmed
Respondent
Before: Karen Hulan (chair), Laura Arndt, Etienne Esquega
Heard: January 7, 2026, by videoconference
Appearances:
Andrea Luey, for the applicant
Respondent, self-represented
Summary:
AHMED – Criminal Offence – Conduct Unbecoming – Agreed Statement of Facts – Penalty and Costs ‒The Lawyer was criminally charged with and plead guilty to assault, mischief under $5,000 and forcible confinement against his former intimate partner – The Lawyer admitted the underlying conduct and that it constituted conduct unbecoming a licensee ‒ The Law Society sought a suspension of three months and the Lawyer asked for no suspension or in the alternative, a suspension of one to two weeks ‒ The panel considered the purposes of penalty orders, the aggravating and mitigating factors and comparable cases and determined that a three-month suspension was necessary to provide general deterrence and to maintain the public’s confidence – The Lawyer was suspended for three months and costs of $4,000 were ordered.
REASONS FOR DECISION
1Karen Hulan (for the panel):– The Law Society alleged that contrary to s 33 of the Law Society Act, RSO 1990, c L.8 (the Act), the Licensee engaged in conduct unbecoming a licensee in regards to his former intimate partner, when he committed the criminal offences of assault, mischief under $5,000 and forcible confinement, for which he was convicted on October 30, 2024.
2The parties entered an agreed statement of facts in which Mr. Ahmed admitted the underlying conduct and that it constituted conduct unbecoming a licensee.
3The Law Society sought a three-month suspension of Mr. Ahmed’s licence to practise law. Mr. Ahmed asked for no suspension of his licence, or alternatively, a suspension of one to two weeks.
4At the hearing, we found conduct unbecoming as alleged and admitted.
5An order on penalty and costs was issued on January 8, 2026. We ordered a three-month suspension of Mr. Ahmed’s licence to practise law effective January 12, 2026, with other terms set out below. These are our reasons for the order.
CONDUCT UNBECOMING
6A Licensee shall not engage in professional misconduct or conduct unbecoming a Licensee: s 33 of the Act.
7The Rules of Professional Conduct define conduct unbecoming as conduct, including in a lawyer’s personal or private capacity, that tends to bring discredit upon the legal profession.
OVERVIEW
8Mr. Ahmed was born in 1986 and was called to the Bar in Ontario in 2021. He previously practised law in Bangladesh. At the time of the conduct unbecoming, he worked as an associate with an Ontario law firm. His primary area of practice was real estate law.
9This matter arose out of incidents of violence on October 13, 2023 against a former intimate partner.
10On October 30, 2024, Mr. Ahmed pled guilty to three Criminal Code offences: one count of common assault; one count of mischief under $5,000; and one count of forcible confinement. He was sentenced to a six-month conditional sentence which included three months of house arrest, followed by one year of probation. The conditional sentence was completed on April 30, 2025. The probation order is scheduled to expire on April 30, 2026.
ADMISSIONS
The incident of violence
11Mr. Ahmed was in a non-cohabiting relationship for about one year with Person A.
12On October 13, 2023, Mr. Ahmed attended Person A’s home, where an argument ensued in her bedroom and she told Mr. Ahmed to leave her home.
13Mr. Ahmed yelled at Person A and pushed her on her shoulders which caused her to fall backwards on the bed. Mr. Ahmed pressed his hand on her chest; he eventually removed it and Person A was able to get off the bed.
14Mr. Ahmed then took a metal water bottle, climbed on top of Person A’s desk and hit a ceiling mounted security camera, causing it to break. He then pulled the camera from the ceiling and threw it to the floor. The camera was inoperable.
15Mr. Ahmed then proceeded to push Person A out of the bedroom and onto the floor where she was held briefly. When she was able to get up, she returned to the bedroom where she was pushed onto the bed a second time.
16Person A was eventually able to leave the bedroom and exited the residence through the front entrance. Mr. Ahmed chased her, grabbed her arm with both hands, pulled her backwards and dragged her toward the front entrance by her arm. Person A grabbed the door frame to avoid being pulled back into the residence.
17Mr. Ahmed then wrapped his arm around her neck and covered her mouth with his other hand.
18Person A was eventually able to flee the residence. She alerted a neighbour who called 911. Police attended and Mr. Ahmed was arrested without incident.
19Person A sustained neck soreness and was assessed by Emergency Services. She declined transport to hospital.
Charges, conviction and sentence
20On October 13, 2023, Mr. Ahmed was charged with assault, assault causing bodily harm, uttering threats to cause death, mischief under $5,000, assault with a weapon and unlawful confinement.
21He was held for a bail hearing and released the following day on a recognizance with a surety and multiple conditions including no contact with Person A.
22Mr. Ahmed complied with his bail conditions without issue.
23Prior to sentencing, Mr. Ahmed successfully completed a 12-session Partner Assault Response Program (“PAR”).
24On October 30, 2024, Mr. Ahmed pled guilty to assault, mischief under $5,000 and forcible confinement.
25A joint submission was accepted by the court. Mr. Ahmed was sentenced to:
a six-month conditional sentence, the first three months of which he was sentenced to house arrest;
followed by a probation order of 12 months with conditions including no contact with Person A;
payment of restitution;
a weapons ban; and,
a DNA order.
26The conditional sentence was completed on April 30, 2025. The probation order is scheduled to expire on April 30, 2026.
Contact with Law Society
27On October 26, 2023, Mr. Ahmed self-reported to the Law Society and disclosed that he was charged with domestic violence offences.
28Mr. Ahmed has no prior discipline history with the Law Society.
Conclusion on conduct
29We find that Mr. Ahmed’s violent actions against Person A tends to bring discredit upon the legal professions and conclude that this amounts to conduct unbecoming as alleged and admitted.
PENALTY
30The Law Society sought a three-month suspension.
31Mr. Ahmed sought no suspension of his licence, or alternatively a suspension of one to two weeks. He distinguished some of the case law provided by the Law Society. He pointed to lesser suspension periods imposed where there were a greater number of incidences (Widz); and, longer suspension periods where there was more serious or extensive misconduct (Subramanian and Aujla).
32Those cases, and others, are reviewed below.
Licensee and citation
Conduct unbecoming
(intimate partner violence)
Penalty Order
Subramanian,
One assault charge and one failure to comply with an undertaking
Joint submission: two-month suspension
Widz,
Two instances of assault; guilty plea to one count of common assault
one-month suspension
Aujla,
Uttering death threat; additional obstructive behaviour
Joint submission: three-month suspension
Kumarasamy,
Conviction of three counts of assault and one count of mischief arising from assaulting his spouse on three occasions
Joint submission: two-month suspension and counselling
33These cases provide us with some general guidance about penalties in cases involving intimate partner violence; however, we recognize that each case has unique facts. Assessment of penalty is not as simple as considering the circumstances of assault or the number of violent acts. It is far more nuanced than that. By their nature, instances of intimate partner violence demonstrate contempt for, or at minimum a disregard of, the dignity of victims. They are harmful to the parties involved, to society at large and to the public’s perception of the legal professions. For this reason, we reject Mr. Ahmed’s submission that there should be no suspension of his licence to practise law. We adopt the panel’s statement in Kumarasamy that, “any case of spousal violence, absent particular mitigating circumstances, should include a suspension to emphasize the profession’s condemnation of such conduct”: Kumarasamy at para 11.
34The goals of penalty are specific deterrence, general deterrence, rehabilitation, and maintaining public confidence in the legal professions and their self-regulation by the Law Society: Widz at para 22.
35Counsel for the Law Society acknowledged in her submissions that there is less concern about specific deterrence as Mr. Ahmed is still currently serving a criminal sentence.
36We agree. Mr. Ahmed entered an agreed statement of facts in the criminal proceeding. The court imposed a significant sentence for his serious criminal offence. He remains under probation. He also entered an Agreed Statement of Facts in this Tribunal proceeding. We then ordered suspension of his licence to practice law and payment of costs. We are satisfied that these penalties address the goal of specific deterrence.
37We view penalty in this matter to be largely concerned with general deterrence and maintaining the public’s confidence in the legal professions. We are satisfied that the views articulated by us in these reasons for decision, as well as the penalty ordered, achieves those important goals of professional regulation.
38We considered mitigating and aggravating factors in this case that were articulated in Law Society of Upper Canada v Aguirre, 2007 ONSLHP 46.
39The following are mitigating factors.
40Mr. Ahmed has no disciplinary history with the Law Society.
41He entered into an agreed statement of facts in the criminal proceeding and in this proceeding. He admitted the conduct unbecoming a licensee. As a result, the Law Society did not need to lead evidence and importantly, Person A was not required to testify.
42He participated in a PAR Program during the criminal proceedings.
43The Law Society submitted that rehabilitative efforts should be, at its highest assessment, a neutral factor because there was no evidence of additional rehabilitation beyond participation in PAR. We do not agree. While additional rehabilitation efforts would be a further mitigating factor, he took steps to address domestic anger abuse. The evidence before us was that he demonstrated a willingness to participate in the program, as well as commitment to learning while maintaining a positive attitude.
44The aggravating factor is the seriousness of the conduct.
45In reaching our conclusion on penalty we considered the particularly reprehensible nature of the events that unfolded on October 13, 2023. Person A was initially physically assaulted in her home. That act alone was enough to warrant a finding of conduct unbecoming, but there was more. The camera in Person A’s bedroom was a security camera. It was deliberately and violently destroyed by Mr. Ahmed. This can be understood to be an attempt to conceal violence which had occurred, or more which would occur in the bedroom. He then physically barred Person A from escaping to safety and when she did escape, he apprehended and attempted to silence her as he dragged her back to her home. This was not one instance of violence perpetrated upon Person A; it was a series of violent acts. The nature of these offences is a significant aggravating factor.
46We also considered that the violence was perpetrated fairly recently, and since the time that each of the decisions cited by the parties were released. As noted by the panel in Widz, at para 35, “partner assault is rightly the subject of increasing public awareness, concern and action, in both the criminal and the regulatory spheres.”
47Legal professionals must note that conduct of this nature may attract increasingly onerous penalties.
48Taking into account the purposes of penalty orders, the aggravating and mitigating factors and comparable cases, we conclude that a three-month suspension is appropriate. We consider that a three-month suspension is necessary given the seriousness of the conduct and the need to provide general deterrence and to maintain the public’s confidence in the legal professions. A three-month suspension sends an appropriate message that this is serious misconduct that is treated seriously.
COSTS
49The Law Society sought payment of costs in the amount of $4,000 to be paid within one year. It submitted a bill of costs totalling $6,695. It did not include Law Society counsel’s time for work performed in the week leading up to the hearing or for her attendance at the hearing.
50Mr. Ahmed requested a reduction in costs payable. There was no evidence of financial hardship, although we appreciate that Mr. Ahmed will not be able to generate income from the practice of law for three months.
51The work outlined on the bill of costs is reasonable as is the reduction of the amount sought. Mr. Ahmed has one year to pay this amount.
ORDER
52We ordered:
The respondent’s licence to practise law is suspended for three months, beginning January 12, 2026.
The respondent shall comply with the Law Society’s Guidelines for Lawyers Who Are Suspended or Who Have Given an Undertaking Not to Practise.
The respondent shall pay costs to the Law Society in the amount of $4,000 on or before January 7, 2027. This deadline may be extended by the Law Society in accordance with the By-Laws. Interest shall accrue on any overdue portion of those costs at a rate of 4% per year.