LAW SOCIETY TRIBUNAL

HEARING DIVISION

Date: March 3, 2026 Tribunal File No.: 25H-034

BETWEEN:

Law Society of Ontario Applicant

• and -

Isaac Owusu-Sechere Respondent

Before: Nicole Treksler (chair), Shalini Konanur, Geneviève Painchaud

Heard: January 15, 2026, by videoconference

Appearances: Tomilayo Ojuile, for the applicant Respondent, self-represented

Summary: OWUSU-SECHERE – Professional Misconduct – Agreed Statement of Facts – Joint Submissions – The Lawyer breached his professional obligations by falsifying a client’s signature, improperly commissioning documents and filing documents without first verifying their contents with the client – He had a previous discipline history ‒ The parties made a joint submission for a proposed penalty of a three month suspension and $5,390 in costs – The panel concluded that the proposed penalty was not so unhinged from the circumstances to require the joint submission be rejected – The Lawyer was suspended for three months and costs in the amount of $5,390 were ordered.

REASONS FOR DECISION

INTRODUCTION

1Nicole Treksler (for the panel):– The respondent, Isaac Owusu-Sechere, was called to the Bar in 1994. He is a sole practitioner practising in immigration and refugee law.

2The Law Society alleges that the respondent breached his professional obligations by falsifying a client’s signature, improperly commissioning documents and filing documents without first verifying their contents with the client.

3The respondent has a previous discipline history with the Law Society of Ontario in 2007 for failure to maintain his books and records and in 2016 for failure to co-operate with a Law Society Investigation and maintain his books and records. He received a six-week suspension in 2016: 2016 ONLSTH 92.

4In October 2025, the respondent signed an agreed statement of facts (ASF) in which he admitted that the conduct described in the notice of application (NOA) was professional misconduct and the facts set out below were agreed. He provided no additional evidence.

5The parties jointly proposed a penalty of a three-month suspension and costs in the amount of $5,390, both to be effective immediately.

6At the hearing, the respondent requested that the costs be deferred to a later date, as he would not be working during the suspension. The Law Society agreed that the respondent pay the costs in full by December 31, 2026.

7We must determine the following:

• whether the particulars in the NOA constitute professional misconduct as alleged; and
• whether the joint submission on penalty and costs is reasonable.

8Based on the ASF including the respondent’s admission, we find that the allegation contained in the NOA constitutes professional misconduct.

9We further find that the joint submission on penalty and costs is appropriate.

10Our reasons follow.

MERITS

11The Law Society alleges that the respondent failed to act with honour and integrity during a solicitor-client relationship with Client A, contrary to Rule 2.1-1 of the Rules of Professional Conduct (the Rules) by:

1. making unauthorized use of Client A’s signature on appeal documents before the Immigration and Refugee Board (IRB);
2. improperly commissioning an affidavit in Client A’s absence; and
3. filing appeal documents without verifying their contents with Client A.

12In December 2021, Client A retained the respondent to file post-hearing submissions related to her refugee claim before the Refugee Protection Division (RPD) of the IRB. The RPD rejected Client A’s claim, and she retained him again to represent her on appeal.

13As the appeal deadline approached, the respondent became unresponsive. Client A eventually terminated the retainer by email. Given that English was not Client A’s first language, the respondent did not understand that she had ended the retainer.

14Even if there was a language barrier, it does not explain or excuse the respondent’s subsequent conduct.

15On May 16, 2022, the respondent prepared appeal documents and used Client A’s signature obtained from a prior matter. He falsely dated the signatures as May 16, 2022.

16The respondent also commissioned the affidavit in Client A’s absence and did not administer the oath or declaration as required by law before signing the jurat or declaration, despite the availability of remote commissioning. He did not review the contents of the affidavit and the record with Client A, nor did he send the documents to her for review before filing them with the Refugee Appeal Division (RAD).

17The respondent later emailed the filed documents to Client A. Client A then contacted the RAD and requested that the documents be disregarded, advising that the respondent no longer represented her.

18Rule 2.1-1 of the Rules requires lawyers to act honourably and conduct themselves to comply with their professional obligations and with applicable law: Law Society of Ontario v McCallum, 2024 ONLSTH 29 at paras 163-165. The Law Society submits that the respondent breached this rule through the conduct above. The respondent admits to these breaches in the ASF.

19The respondent did not provide any further evidence.

20Based on the ASF and the Law Society’s submissions, we find that the allegations of professional misconduct are proven.

21We turn next to penalty and costs.

PENALTY

22The parties jointly proposed a three-month suspension, to be effective immediately.

23The “public interest” threshold for rejecting a joint submission is “undeniably high.” A panel may reject a joint submission only where it is “so unhinged … that its acceptance would lead reasonable and informed persons, aware of all the relevant circumstances, including the importance of promoting certainty in resolution discussions, to believe that the proper functioning of the justice system had broken down.” R. v Anthony-Cook, 2016 SCC 43 at para 34, and Law Society of Ontario v Archambault, 2017 ONLSTH 86 at para 13.

24The Divisional Court has confirmed that these principles also apply to professional discipline proceedings: Bradley v Ontario College of Teachers, 2021 ONSC 2303.

25We accept the joint submission. Considering the seriousness of the misconduct and the range of penalties imposed in comparable cases, the proposed penalty does not approach the high threshold required to justify rejection.

26The respondent’s conduct was serious and undermined public confidence in the profession. It involved falsifying Client A’s signature, improperly commissioning documents, and filing materials without verifying their contents with the client. This conduct reflects a lack of integrity and honour, which are foundational obligations of the legal profession.

27Mitigating factors include the respondent’s acceptance of responsibility through the ASF, his admission of misconduct, and his expression of remorse at the hearing.

28Aggravating factors include the respondent’s previous discipline history, including findings related to record-keeping in 2006 and a failure to co-operate with a Law Society investigation in 2017. While dated, the history remains relevant to the assessment of penalty.

29In comparable cases involving forged or falsified documents, suspensions have ranged from four to 12 months, often in combination with additional misconduct, which is not present in this matter: Law Society of Ontario v Twizell, 2024 ONLSTH 38 at paras 20-28.

30The following cases illustrate the range of penalties imposed for falsifying or forging documents:

• Manilla, 2021 ONLSTA 25: The lawyer forged his client’s name on five court documents filed on two motions. A three-month suspension was ordered.
• Chung, 2021 ONLSTH 44: The paralegal’s misconduct included: entering guilty pleas without client instructions; misleading the court that he had client authorization; forging and commissioning false affidavits and providing false information during a Law Society investigation. A 12-month suspension was ordered.
• Osadet, 2022 ONLSTH 138: False document misconduct; a 30-day suspension was ordered.
• Wu, 2022 ONLSTH 82: False document misconduct; a two-month suspension was ordered.

31Of these cases, Manilla is the closest to the facts of the present case given the absence of other compounding factors found in other cases.

32In all the circumstances, we find that a three-month suspension is consistent with jurisprudence, reflects the seriousness of the misconduct, promotes both specific and general deterrence, and protects the public. Accordingly, the public interest test is not met, and we are required to accept the joint submission.

COSTS

33The parties agreed to costs of $5,390. Although costs were originally payable immediately, the respondent requested time to pay due to the suspension. The Law Society agreed that costs be paid in full by December 31, 2026.

34We accept the well-established principle that the professions should not bear the costs of disciplinary proceedings: Law Society of Upper Canada v Baker, 2006 ONLSHP 21 at para 12. That said, Tribunal jurisprudence recognizes that costs may be reduced where a respondent has been cooperative or where there are other mitigating or extenuating circumstances, including financial hardship.

35In this matter, the Law Society’s bill of costs exceeded $10,000, which was reduced by approximately half. This reduction reflects the respondent’s co‑operation throughout the proceedings, the existence of an ASF, and the joint submissions on both penalty and costs. In these circumstances, the agreed amount is consistent with Tribunal precedent.

36We therefore find that both the amount of costs and the timeframe for payment are reasonable and appropriate.

ORDER

37We made the following order:

1. The respondent’s licence to practise law shall be suspended for three months, effective immediately.
2. The respondent shall comply fully with the terms of the Law Society’s Guidelines for Lawyers Who Are Suspended or Who Have Given an Undertaking Not to Practise while suspended pursuant to this order.
3. The respondent shall pay costs to the Law Society in the amount of $5,390 by Thursday, December 31, 2026. This deadline may be extended by the Law Society in accordance with the By-Laws. Interest shall accrue on any overdue part of those costs at a rate of 4% per year.