LEGAL SERVICES AND COMPLAINTS COMMITTEE -v- WILLIAMSON [2026] WASC 347

[2026] WASC 347 Page 1 JURISDICTION : SUPREME COURT OF WESTERN AUSTRALIA IN CIVIL TITLE OF COURT : FULL BENCH CITATION : LEGAL SERVICES AND COMPLAINTS COMMITTEE -v- WILLIAMSON [2026] WASC 347 CORAM : QUINLAN CJ MCGRATH J HILL J HEARD : 5 AUGUST 2026 DELIVERED : 5 AUGUST 2026 PUBLISHED : 21 AUGUST 2026 FILE NO : LPD 3 of 2026 BETWEEN : LEGAL SERVICES AND COMPLAINTS COMMITTEE Plaintiff AND RHETT PETER WILLIAMSON Defendant Catchwords: Legal practitioners – Disciplinary proceedings – Removal from roll of practitioners – Practitioner not a fit and proper person to remain a legal practitioner -- 1 of 19 -- [2026] WASC 347 Page 2 Legislation: Legal Profession Act 2008 (WA) Legal Profession Uniform Law (WA) State Administrative Tribunal Act 2004 (WA) Result: Order that the practitioner's name be removed from the roll of practitioners Representation: Counsel: Plaintiff : J Winton & J A Colella Defendant : No appearance Solicitors: Plaintiff : Legal Services and Complaints Committee Defendant : No appearance Cases referred to in decision: Council of the Law Society of New South Wales v Clifton [2021] NSWCA 340. Law Society of the ACT v Powrie [2017] ACTSCFC 4; (2017) 12 ACTLR 184. Legal Profession Complaints Committee v Chin [2012] WASC 467. Legal Profession Complaints Committee v In De Braekt [2013] WASC 124. Legal Profession Complaints Committee v Oud [2019] WASC 287. -- 2 of 19 -- [2026] WASC 347 REASONS OF THE COURT Page 3 REASONS OF THE COURT: 1 On 5 August 2026, we ordered that Rhett Peter Williamson's name be removed from the roll of practitioners of this Court. Mr Williamson consented to the order. 2 We said that we would publish our reasons later. These are our reasons. 3 In short, Mr Williamson is not fit to be a legal practitioner. The evidence before the Court demonstrated that he had engaged in a range of disgraceful conduct that was wholly inconsistent with the privileges of legal practice. He threatened and abused a client and the client's family, he lied to the Legal Practice Board (Board) and, in order to cover up his threats and lies, acted contrary to the interests of another client. 4 There could be no doubt that Mr Williamson does not have the qualities of honesty and integrity demanded of an officer of this Court. Procedural background 5 On 2 April 2026, the State Administrative Tribunal (Tribunal) made an order, pursuant to s 438 of the Legal Profession Act 2008 (WA) (the Act), that a report be transmitted to the Full Bench of this Court of the Tribunal's findings that Mr Williamson had engaged in professional misconduct within the meaning of s 403 of the Act, with a recommendation pursuant to s 302(1)(f) of the Legal Profession Uniform Law (WA) (Uniform Law) that Mr Williamson's name be removed from the roll of persons admitted to the legal profession. 6 The report of the Tribunal was transmitted to this Court on 14 April 2026. It was comprised of the orders of the Tribunal dated 2 April 2026, and a Statement of Agreed Facts, being a statement agreed between the parties as to the relevant facts upon which the matter before the Tribunal could be settled. 7 On 1 May 2026, the Legal Services and Complaints Committee (Committee) filed an originating motion for an order that Mr Williamson's name be removed from the roll of practitioners of the Court, pursuant to s 23(1) of the Uniform Law. 8 The Statement of Agreed Facts and the orders of the Tribunal follow a practice, all too common in matters of this type, of replacing -- 3 of 19 -- [2026] WASC 347 REASONS OF THE COURT Page 4 the names of all individuals referred to in narrative with letters of the alphabet. The material transmitted before this Court accordingly included no record of the identities of any of the persons involved. 9 This practice should be discouraged. It gives rise to at least two difficulties. 10 First, at a practical level, it makes the narrative set out in the Statement of Agreed Facts, which at times resembles an algebraic equation, extremely difficult to follow. Secondly, and more substantively, it prevents the members of this Court from determining whether, by reason of a personal or professional relationship with any of the persons concerned, they may be prevented from hearing the application. 11 At the hearing of the application, the Court was advised as to the identity of the persons referred to in the Statement of Agreed Facts. In what follows all of the persons referred to, other than the practitioner, have been referred to by pseudonyms. Statement of Agreed Facts 12 Mr Williamson was admitted to legal practice on 19 December 2011 and at all material times prior to 1 July 2022 was an Australian legal practitioner within the meaning of the applicable legislation, trading as a sole practitioner as Williamson Criminal Lawyers. Complaint in relation to Mr Michael Andrews 13 In approximately August 2020, Mr Michael Andrews was charged with criminal offences in the Magistrates Court (Charges), from which time until 29 March 2021, Mr Williamson represented Mr Andrews in relation to the Charges. 14 In March 2021, Mr Andrews was remanded in custody. On 11 March 2021, Mr Williamson visited Mr Andrews in custody, and alleged that Mr Andrews owed him $3,500 in outstanding fees for his legal services, and advised that he (Mr Williamson) had attempted to contact Mr Andrews' parents to obtain payment of the outstanding fees, but they had ignored him. Mr Andrews provided Mr Williamson with the contact details of his brother, John Andrews. 15 On 29 March 2021, Mr Williamson attended the Fremantle Magistrates Court for the trial of the Charges. John Andrews was present. Mr Andrews terminated Mr Williamson's retainer prior to the -- 4 of 19 -- [2026] WASC 347 REASONS OF THE COURT Page 5 trial. Mr Williamson spoke to John Andrews and asked whether John Andrews would pay the outstanding fees, which John Andrews declined to do. 16 Mr Williamson then sent Mr Andrews' father (Mr Andrews Snr) a text message in the following terms: Hey [Mr Andrews Snr], [Michael] withdrew his instructions for me to act today in court, when [we] were about to start the trial. So before I can hand over the file and all evidence over (sic) to alternative counsel, I need my outstanding bill settled, which is $3,500. Please advise when I can expect to receive payment? 17 On 29 March 2021, between 1.28 pm and 1.39 pm, Mr Williamson sent Mr Andrews Snr the following text messages: Haha you think I am not a real lawyer? Get the bill paid, end of story, or read it in The West. I do not work for free. I have enough people in jail that owe me favours, so I will leave the ball in your court. 18 On 29 March 2021, at 10.07 pm, Mr Williamson sent John Andrews the following text message: Hey [John], tell [Michael] I have met up with [Stuart Mitchell] this arvo, and he said if [Michael] does not pay his legal fees that he will come to court and testify against him. 19 On 30 March 2021, between 12.37 am and 12.52 am, Mr Williamson sent Mr Andrews' mother (Mrs Andrews) the following text messages: You can ignore me all you want [Mrs Andrews], but you have a poofter son and a lesbian daughter. The only straight child you have is a fucked up meth addict in jail who set your house on fire. Fucking winning at life. And I already have been in touch with people in jail that want to bash him for not paying his bills. Obviously I can stop that from happening, but I will give you the 28 days until the account is paid. You know the funny part [Mrs Andrews], I do not even have to pay these cunts to bash [Michael]. They said they are just going to do it as a favour […] 20 All of the text messages were sent for the purpose, or substantial purpose, of improperly seeking to coerce Mr Andrews' relatives to pay, or cause Mr Andrews to pay, Mr Williamson's outstanding legal costs for acting for Mr Andrews. -- 5 of 19 -- [2026] WASC 347 REASONS OF THE COURT Page 6 21 John Andrews made a complaint about the text messages to the Legal Profession Complaints Committee (LPCC) at 9.47 am on 30 March 2021. At 10.37 am that day, Mr Williamson sent a text message to Mrs Andrews which stated: Please ignore all messages I sent yesterday. I was high on Xanax and alcohol and have a complete blackout. I am sorry. I wish no harm on [Michael] or his family. I will not contact any of you ever again, I am deleting your numbers from my phone. Misleading the Legal Practice Board 22 On 8 April 2021, the Professional Affairs Committee (PAC) of the Board resolved to propose to cancel Mr Williamson's practising certificate on the basis of the complaint made by John Andrews. 23 On 9 April 2021, the PAC gave notice to Mr Williamson, pursuant to s 56(2) of the Act, of the proposed cancellation of his practising certificate and invited him to make representations on that proposed action. On 30 April 2021, Mr Williamson provided a statutory declaration (Statutory Declaration) to the PAC in which he admitted that the text messages had been sent from his phone, but denied having sent them, or causing them to be sent. He asserted that the text messages had been sent without his knowledge or consent by Mr Stuart Mitchell. 24 Attached to the Statutory Declaration was a handwritten statement which Mr Williamson claimed was written by Mr Mitchell (Handwritten Statement). The Handwritten Statement purported to contain an admission by Mr Mitchell that he had sent the text messages from Mr Williamson's phone without his knowledge or consent. 25 Mr Williamson's denial as to having sent the text messages, his assertion that Mr Mitchell had sent them from his phone without his knowledge or consent, and the Handwritten Statement: (a) each represented to the PAC that Mr Williamson had not sent, or had not caused to be sent, the text messages; (b) were, to the knowledge of Mr Williamson, false and misleading, in that Mr Williamson had sent, or caused to be sent, the text messages; and (c) were intended by Mr Williamson to mislead the PAC. -- 6 of 19 -- [2026] WASC 347 REASONS OF THE COURT Page 7 Complaint in relation to Ms Brooks 26 In September 2018, Ms Catherine Brooks commenced a personal relationship with Mr Mitchell. Ms Brooks had two children, with Mr Mitchell being the father of the youngest. 27 In March 2020, Ms Brooks applied for and was granted a family violence restraining order (FVRO) against Mr Mitchell. 28 On 22 August 2020, Ms Brooks suffered injuries (Injuries) while at Mr Mitchell's residence. Ms Brooks gave a statement to police dated 1 September 2020, in which she alleged that Mr Mitchell had inflicted the Injuries, and that he had called her the following day, asking her to remove the family violence restraining order and to tell police he had not caused the Injuries. 29 After Ms Brooks suffered the Injuries, the children were taken into care by the Department of Communities (Department). On 31 August 2020, the Chief Executive Officer of the Department applied for a protection order (time limited) (Protection Order) in respect of the children (Protection Application). Pending the determination of the Protection Application, the children were placed in the care of Ms Brooks' mother, Mrs Brooks. 30 On 12 November 2020, Ms Brooks obtained a final FVRO against Mr Mitchell. 31 Mr Mitchell objected to the Protection Application and sought to have his child placed in his care and custody. That objection and the Protection Application were listed for hearing on 5 July 2021. 32 Mr Mitchell believed that the existence of the FVRO would adversely impact on the prospects of success of his objection to the Protection Application or make it more likely that the Protection Application would be granted. 33 In or about January 2021, Ms Brooks was charged and convicted of an offence, for which she was imprisoned until 12 July 2021. 34 Prior to 22 March 2021, Ms Julie Hopewell, a legal practitioner, was engaged by Mrs Brooks to assist Ms Brooks with the Protection Application. 35 On 12 April 2021, Mr Williamson asked Mr Mitchell to provide the Handwritten Statement. In exchange for him doing so, -- 7 of 19 -- [2026] WASC 347 REASONS OF THE COURT Page 8 Mr Williamson agreed with Mr Mitchell that he would act pro bono for Ms Brooks in relation to the FVRO and in the course of acting for her, to: (a) communicate with Ms Brooks on behalf of Mr Mitchell while he was restrained from doing so by the FVRO; and (b) cause, or counsel, Ms Brooks to cancel the FVRO (Agreement). 36 On 20 April 2021, Mr Williamson booked an appointment to visit Ms Brooks in custody on 27 April 2021. Prior to the visit, Mr Mitchell called Ms Brooks in custody five times, telling her that Mr Williamson was his 'best mate' and would be coming to visit her, that Mr Williamson would be her lawyer, and would tell her what to do, including to remove the FVRO. 37 Ms Brooks later told her mother that she did not have to pay Ms Hopewell and that Ms Brooks now had her own lawyer. 38 Mr Williamson did not attend his booked visit with Ms Brooks on 27 April 2021. On 5 May 2021, Mr Mitchell called Ms Brooks and told her that Mr Williamson would try to put some money in her prison account. After that call, Mr Williamson visited Ms Brooks in custody. 39 During that visit, Ms Brooks signed an 'authority to act', which authorised Mr Williamson to act as her counsel in 'all my legal matters before court and all other associated matters on my behalf.' Mr Williamson told Ms Brooks that Mr Mitchell wanted her to cancel the FVRO, and recorded instructions from Ms Brooks to vary, but not cancel the FVRO. 40 Mr Williamson later tried to deposit money in Ms Brooks' private prison account, but prison staff refused to let him. 41 Mr Mitchell and Ms Brooks spoke on the telephone later that day. They discussed Mr Williamson's visit and his failed attempt to deposit money into Ms Brooks' prison account. Mr Mitchell told Ms Brooks that Mr Williamson had filed an application to cancel the FVRO and that Ms Brooks had 'no current VRO against [Mr Mitchell]'. 42 Ms Brooks noted that Mr Williamson had been shaking during their meeting and queried whether 'he had a big night or something', to which Mr Mitchell replied 'yeah, he did [laughs]. He does every day'. -- 8 of 19 -- [2026] WASC 347 REASONS OF THE COURT Page 9 43 Mr Mitchell and Ms Brooks spoke on the telephone an hour later. During that telephone call, Mr Mitchell told Ms Brooks that he was with Mr Williamson, and they joked about him having a 'big night' the night before. Ms Brooks told Mr Mitchell that she was on medication, which Mr Mitchell relayed to Mr Williamson, who then expressed his views on what the medication was usually prescribed for. 44 In a further telephone call between Mr Mitchell and Ms Brooks a short time later, Mr Mitchell queried whether Ms Brooks had told Mr Williamson that Mr Mitchell was an alcoholic, and Ms Brooks complained that Mr Williamson had 'broke[n] confidentiality right there'. 45 On 11 May 2021, Mr Williamson visited Ms Brooks in custody at 8.30 am and obtained further instructions about the FVRO. In a phone call between Mr Mitchell and Ms Brooks later that day, Mr Mitchell told Ms Brooks that Mr Williamson had, in effect, difficulty varying the FVRO and was seeking further information from the prison. Mr Williamson subsequently called an Assistant Superintendent at the prison, requesting information about Ms Brooks and the FVRO, and details were then emailed to Mr Williamson. 46 On 12 May 2021, Ms Brooks called Mr Mitchell, who was then with Mr Williamson. Ms Brooks told Mr Mitchell that she wanted to cancel the FVRO, and Mr Mitchell told Mr Williamson this and gave him the telephone. Ms Brooks asked Mr Williamson whether Mr Mitchell had cancelled the FVRO he had against her, and Mr Williamson confirmed he had not. 47 Mr Mitchell told Ms Brooks, through Mr Williamson, that he would not cancel his FVRO against Ms Brooks 'until I get the court case over with', in reference to the Protection Application. Mr Mitchell told Ms Brooks, through Mr Williamson, that 'she needs to cancel her [FVRO] straight away'. 48 Later that day, Ms Brooks called Mr Mitchell, who told Ms Brooks to call her lawyer, and that prison authorities were not permitted to listen to calls between her and her lawyer. When Ms Brooks called Mr Mitchell again about 90 minutes later, Mr Mitchell told Ms Brooks that he was 'at the bar' with Mr Williamson. 49 On 13 May 2021, Ms Brooks called Mr Mitchell. During this call, Mr Mitchell told her that Mr Williamson would be visiting her to have -- 9 of 19 -- [2026] WASC 347 REASONS OF THE COURT Page 10 her sign a form to cancel the FVRO and told her she had to cancel it, even though he was not cancelling his. Mr Mitchell said that Mr Williamson would explain it to her. Two hours later, Ms Brooks again called Mr Mitchell, and Mr Mitchell told her that he was 'having a chat with [Mr Williamson]' and was 'always with [Mr Williamson]'. 50 On 17 May 2021, Mr Williamson visited Ms Brooks in custody, and communicated Mr Mitchell's desire for Ms Brooks to cancel the FVRO and recorded Ms Brooks' instructions to cancel the FVRO and to deliver a present to her eldest child for their birthday. 51 Later that day, Mr Williamson filed an application to cancel the FVRO in the Perth Magistrates Court. He then attended Mrs Brooks' house, in a car driven by Mr Mitchell. Mr Williamson was dressed in casual clothes. He told Mrs Brooks he was Ms Brooks' lawyer and said that he had brought a birthday present for her child. Mrs Brooks took the present, but did not believe Mr Williamson and asked him to leave. Mrs Brooks then noticed Mr Mitchell was parked on her verge. She approached the car, and told Mr Mitchell to leave. Mr Williamson then got into the car and was driven away by Mr Mitchell. 52 On the same date, the PAC wrote to Mr Williamson and informed him that, based on the Statutory Declaration and Handwritten Statement, no further action would be taken by the PAC against him in respect of the complaint regarding the text messages relating to Mr Andrews at that time. 53 On 21 May 2021, Mrs Brooks had an appointment with Ms Hopewell, during which Mrs Brooks told Ms Hopewell about what had happened on 17 May 2021. Following the appointment, Ms Hopewell spoke to Ms Brooks on the telephone, during which Ms Brooks said that: (a) Ms Hopewell was still 'her lawyer'; (b) Mr Williamson was 'helping her in relation to a criminal matter'; (c) she did not know who was paying Mr Williamson; and (d) in response to a query about her position in respect of the Protection Application, she was confused, did not know who to trust, and would think about it and call Ms Hopewell back. -- 10 of 19 -- [2026] WASC 347 REASONS OF THE COURT Page 11 54 On 25 May 2021, Ms Hopewell called Ms Brooks, during which Ms Brooks said that Mr Williamson was visiting her on 27 May 2021 and she still didn't know what to do in relation to the Protection Application. 55 On 27 May 2021, Mr Williamson visited Ms Brooks in custody during which he again told Ms Brooks that Mr Mitchell wanted her to cancel the FVRO and indicated that he had filed an application to that effect. 56 On 3 June 2021, Ms Hopewell made a complaint about Mr Williamson's conduct in relation to Ms Brooks to the Board and, in particular, raised a concern that Mr Williamson was 'being instructed and paid by Mr Mitchell to approach young [Ms Brooks], pretending to want to help her, with the purpose of persuading her to revoke the FVRO against [Mr Mitchell]; and to change her position thus strengthening his objection to the [Protection Application]' (Conflict Complaint). 57 On 16 June 2021, the Board issued Mr Williamson with a notice, pursuant to s 520 of the Act (First Notice), requiring Mr Williamson to provide information relevant to the Conflict Complaint and to answer, relevantly and in effect: (a) whether he was, or had ever been, Mr Mitchell's lawyer; (b) whether he had any non-professional relationship with Mr Mitchell; (c) whether he was, or had ever been, Ms Brooks' lawyer; and (d) whether he had ever visited Ms Brooks in custody. 58 On 23 June 2021, Ms Brooks was interviewed by custodial staff. She told them that Mr Williamson had been communicating with her on behalf of Mr Mitchell and asked that Mr Williamson be removed from her prisoner telephone system account. 59 On 28 June 2021, Mr Williamson visited the prison. However, custodial staff refused to let him visit Ms Brooks in person. Mr Williamson then claimed to be visiting Ms Brooks on behalf of a barrister, Ms Ingrid Stevens, who was representing Mr Mitchell in the Protection Application. He also claimed to represent Mr Mitchell in relation to the Protection Application. -- 11 of 19 -- [2026] WASC 347 REASONS OF THE COURT Page 12 60 When asked if it was appropriate that he meet with Ms Brooks on behalf of the other party to the FVRO, Mr Williamson said that he wished to speak to her in an attempt to find 'common ground' before the Protection Application. 61 Custodial staff spoke to Ms Brooks, who said that Mr Williamson was not her lawyer but that she would hear what he had to say, and Mr Williamson was allowed to speak to Ms Brooks by telephone. After that telephone call, Ms Brooks informed custodial staff that she wished for Mr Williamson to leave the prison. 62 On 29 June 2021, Ms Stevens was contacted by custodial staff and asked whether Mr Williamson had briefed her or whether she represented Mr Mitchell, and she confirmed that she acted for Mr Mitchell, but denied having any professional relationship with Mr Williamson or having sent him to the prison on her behalf. Later that day, she contacted Mr Williamson by text, stating: Rhett, if you are attending prison facilities advising that you are attending to see inmates at my instruction I put you on notice that I will report you to the LPB. You have never briefed me in any matters and I have never given you any instructions of any kind. I hope that you have not been using my name in any form of misrepresentation. 63 Mr Williamson responded by text: Sorry [Ms Stevens], I mentioned your name by accident, because they put me on the spot and I was actually visiting her independently but for some reason they were questioning why I was visiting her, which is none of their business. 64 On 30 June 2021, Mr Williamson applied to have his phone number added to Ms Brooks' approved prisoner telephone list and identified his relationship as 'lawyer'. 65 On 30 June 2021, Mr Williamson responded to the First Notice (First Response), in which he, relevantly and in effect: (a) denied having ever acted for Mr Mitchell; (b) asserted that he only knew Mr Mitchell 'on a strictly casual basis […] from occasionally drinking at the pub where he drinks. Our relationship is not one that I would declare as a friendship'; -- 12 of 19 -- [2026] WASC 347 REASONS OF THE COURT Page 13 (c) admitted acting for Ms Brooks on a pro bono basis in relation to the FVRO; (d) stated that he had never met Ms Brooks before being engaged by her on 5 May 2021; (e) claimed that he had been contacted by an unknown female, who he believed was named 'Bella', who had asked him to attend the prison to provide legal advice to Ms Brooks about cancelling the FVRO; and (f) asserted that he had no conflict of interest arising from his association with Mr Mitchell. 66 On 2 July 2021, Mr Williamson called the prison. He asked to speak to Ms Brooks, but she told custodial staff that she did not wish to have any further communication with Mr Williamson. Failure to comply with summonses 67 On 6 January 2022, the Board issued Mr Williamson with a summons, pursuant to s 520 of the Act, in relation to the complaint made in relation to Mr Andrews (First Summons), requiring documents to be produced in relation to the matter by 20 January 2022. Mr Williamson failed, without reasonable excuse, to comply with the First Summons by the due date, or at all. 68 On 9 May 2023, the Committee commenced disciplinary proceedings against Mr Williamson in the Tribunal for other matters. 69 On 19 October 2023, the Board issued Mr Williamson with a summons pursuant to s 520 of the Act, in relation to the matters relating to Mr Andrews and the Conflict Complaint (Second Summons). He was required to comply by 3 November 2023. Without reasonable excuse, he did not comply by that date, or at all. 70 Mr Williamson's failure to comply with the First Summons and the Second Summons had the purpose, or substantial purpose, of seeking to obstruct the Board's investigations into the matters involving Mr Andrews and the Conflict Complaint, and did in fact have that effect. 71 On 23 November 2023, Mr Williamson provided the Board with an undertaking that he would not engage in legal practice until, amongst other things, he had complied with the second summons. -- 13 of 19 -- [2026] WASC 347 REASONS OF THE COURT Page 14 72 On 20 December 2023, the Committee resolved to refer Mr Williamson's conduct in respect of the matters involving Mr Andrews and the Conflict Complaint to the Tribunal, pursuant to s 428 of the Act. 73 A complaint was also initiated against Mr Williamson in respect of his failure to comply with the First Summons and the Second Summons. Mr Williamson failed to comply with a subsequent notice, issued pursuant to s 371 of the Uniform Law, regarding that failure to comply. Mr Williamson failed to comply with that notice within the required time, or at all. 74 On 28 May 2024, the Committee resolved to initiate and prosecute proceedings, pursuant to s 300(1) of the Uniform Law, against Mr Williamson in respect of his failure to comply with the First Summons and the Second Summons. Agreed facts relevant to sanction 75 On 20 March 2018, Mr Williamson was publicly reprimanded for unsatisfactory professional conduct for failures of competence and diligence relating to the failure to properly prepare for, appear at, and advise his client in respect of a sentencing hearing. 76 On 17 January 2025, the Tribunal found that: (a) between about 16 March 2015 and 12 September 2016, Mr Williamson engaged in unsatisfactory professional conduct by: (i) failing to provide his client disclosure as to his legal costs; and (ii) failing to notify the client of his rights in respect of his legal costs; (b) between 21 April 2016 and 13 March 2018, Mr Williamson engaged in professional misconduct by: (i) applying for, and making submissions in support of, a costs order in favour of the client, in circumstances where the respondent was grossly careless as to whether the application and his submissions contained representations that were false and misleading and as to -- 14 of 19 -- [2026] WASC 347 REASONS OF THE COURT Page 15 whether the Court would be misled by those representations; and (ii) dishonestly retaining costs ordered by the Court to be paid to the client by the State of Western Australia in circumstances where: A. Mr Williamson knew that he had an obligation to refund the client the sum of $2,200; and B. Mr Williamson was recklessly indifferent as to whether he had any entitlement to the balance of the costs awarded to the client. 77 The Tribunal ordered, pursuant to s 439(b) of the Act, that the respondent not be granted an Australian practising certificate before the end of a period of seven months commencing from the date of those orders and ordered Mr Williamson to pay the Committee's costs in the amount of $10,000. 78 Mr Williamson has not otherwise previously been the subject of any disciplinary findings or proceedings. 79 Mr Williamson has demonstrated insight into the seriousness of his conduct in this matter by agreeing to the findings that he engaged in professional misconduct. 80 By reaching an agreement with the Committee and the Board in respect of these applications, Mr Williamson has avoided the need for a hearing, with the result that the resources and time of the Tribunal and the Committee have been saved. The orders of the Tribunal as to the conduct of the respondent 81 On the basis of the agreement between the Committee and Mr Williamson, the Tribunal ordered, pursuant to s 56(1) of the State Administrative Tribunal Act 2004 (WA) that: (a) [Mr Williamson], on or about 29 and 30 March 2021, engaged in professional misconduct within the meaning of s 403(1)(b) of the [Legal Profession Act 2008 (WA) (LP Act)], as applied by s 37 of the Interpretation Act 1984 (WA) ('Interpretation Act'), which conduct would also be reasonably regarded as disgraceful and dishonourable to practitioners of good repute and competence, in the course of acting for [Mr Andrews] in relation to criminal charges in the Magistrates Court, in that -- 15 of 19 -- [2026] WASC 347 REASONS OF THE COURT Page 16 [Mr Williamson] sent, or caused to be sent, text messages to relatives of [Mr Andrews] which were: (i) offensive, abusive, and threatening; and (ii) sent for the purpose, or substantial purpose, of improperly seeking to coerce those relatives to pay, or cause [Mr Andrews] to pay, [Mr Williamson's] outstanding legal costs for acting for [Mr Andrews]; (b) [Mr Williamson], on 30 April 2021, engaged in professional misconduct within the meaning of s 403(1)(b) of the LP Act, as applied by s 37 of the Interpretation Act, which conduct would also be reasonably regarded as disgraceful and dishonourable to practitioners of good repute and competence, in the course of responding to the proposal by the Professional Affairs Committee ('PAC') of the Board to cancel his practising certificate, in that [Mr Williamson]: (i) provided the PAC with a statutory declaration from him that contained statements that were, to [Mr Williamson's] knowledge, false and misleading; (ii) provided the PAC with a handwritten letter from [Mr Mitchell], which to [Mr Williamson's] knowledge contained false and misleading statements, corroborating [Mr Williamson's] false and misleading statements in his statutory declaration; and (iii) intended that the PAC be misled by those false and misleading statements; (c) [Mr Williamson], between 12 April 2021 and 2 July 2021, engaged in professional misconduct within the meaning of s 403(1)(b) of the LP Act, as applied by s 37 of the Interpretation Act, which conduct would also be reasonably regarded as disgraceful and dishonourable to practitioners of good repute and competence and that, to a substantial degree, fell short of the standard of professional conduct observed or approved by members of the profession of good repute and competence, in the course of acting for [Ms Brooks] in relation to a family violence restraining order ('FVRO') restraining [Mr Mitchell], in that [Mr Williamson]: (i) acted for [Ms Brooks] pro bono in return for [Mr Mitchell] having provided a handwritten letter to the PAC corroborating [Mr Williamson's] false and misleading statements ('Agreement') and, pursuant to that Agreement: -- 16 of 19 -- [2026] WASC 347 REASONS OF THE COURT Page 17 (A) caused [Ms Brooks] to cancel the FVRO in furtherance of [Mr Mitchell's] interests, rather than [Ms Brooks'] interests; and (B) knowingly assisted [Mr Mitchell] in breaching the FVRO by communicating with [Ms Brooks] on behalf of [Mr Mitchell] while he was restrained from doing so; and (ii) acted for [Ms Brooks] in circumstances where [Mr Williamson] knew, or ought to have reasonably known, that there was an actual conflict between [Mr Williamson's] interests, by reason of the Agreement, and those of [Ms Brooks]; and (d) [Mr Williamson], between 6 January 2022 and continuing during the investigation by the Board of complaints made against him in relation to his conduct in relation to grounds one to three above ('Complaints'), engaged in professional misconduct within the meaning of s 297(1)(b) of the Uniform Law, which conduct would also reasonably be regarded as disgraceful or dishonourable by practitioners of good repute and competence, and that, to a substantial degree, fell short of the standard of professional conduct observed or approved by members of the profession of good repute and competence, in that [Mr Williamson] failed to comply, without reasonable excuse, and for the purpose, or substantial purpose, of seeking to obstruct the Board's investigation into the Complaints, with two summonses issued, pursuant to s 520 of the LP Act, to [Mr Williamson] by an investigator. Statutory framework and relevant principles 82 The application to this court is made pursuant to s 23(1)(c) of the Uniform Law, which relevantly provides that the Supreme Court may order the removal of the name and other particulars of a person from the Supreme Court roll1 on the recommendation of the designated tribunal, which in this State is the State Administrative Tribunal.2 83 There is authority for the proposition that the report made by the Tribunal is conclusive as to all facts and findings mentioned or 1 The roll of persons admitted to the legal profession maintained by the Supreme Court under s 28(1) of the Act continues from 1 July 2022 as the Supreme Court roll, which is required to be maintained under s 22(1) of the Uniform Law: Legal Profession Uniform Law Application Act 2022 (Application Act). 2 Application Act, s 22. -- 17 of 19 -- [2026] WASC 347 REASONS OF THE COURT Page 18 contained in the report.3 In these proceedings there is no challenge as to the facts or findings or their conclusiveness. 84 A report from the Tribunal does not automatically result in an order that a practitioner be removed from the roll of practitioners. The court must satisfy itself that the practitioner is not a fit and proper person to practise law and that it is appropriate to remove their name from the roll.4 85 The principles to be applied in an application such as this are well established, and were summarised by this Court in Legal Profession Complaints Committee v Oud as including:5 (a) the court's jurisdiction with respect to the regulation of the legal profession is not to be exercised for the purpose of punishing the practitioner concerned, but for the protection of the public and the maintenance of the reputation and standards of the legal profession; (b) where the motion is to remove a practitioner from the roll, the critical question for the court is whether the practitioner is shown not to be a fit and proper person to be a legal practitioner; (c) fitness to practice law requires that the practitioner must command the personal confidence of his or her clients, fellow practitioners and judges; (d) removal from the roll is an order reserved for very serious cases, where the character and conduct of the practitioner is seen to be inconsistent with the privileges of further practice; and (e) integrity and honesty are essential characteristics expected of a practitioner, and therefore, the court has generally taken a very serious approach when dealing with dishonesty by a practitioner. Disposition 86 There can be no doubt that the conduct engaged in by Mr Williamson demonstrates that he is not a fit and proper person to be a lawyer. That conduct, as a whole, reveals a character that is the antithesis of that required of a legal practitioner. While it is to Mr Williamson's credit that he, ultimately, showed some insight into his 3 Council of the Law Society of New South Wales v Clifton [2021] NSWCA 340; Law Society of the ACT v Powrie [2017] ACTSCFC 4; (2017) 12 ACTLR 184 [79]. 4 Legal Profession Complaints Committee v Chin [2012] WASC 467 [19]; Legal Profession Complaints Committee v In De Braekt [2013] WASC 124 [31]. 5 Legal Profession Complaints Committee v Oud [2019] WASC 287 [17]. -- 18 of 19 -- [2026] WASC 347 REASONS OF THE COURT Page 19 unfitness by agreeing to the findings made by the Tribunal, that unfitness remains. 87 It is difficult to identify which aspect of Mr Williamson's conduct was the most egregious. Certainly his threatening and abusive communications to Mr Andrews' family were the most colourful and striking. That a legal practitioner could communicate in this way with anyone, let alone to persons connected with a former client, beggars belief. 88 Ultimately, however, Mr Williamson's unfitness for legal practice is revealed most starkly by his conduct towards Ms Brooks. The facts reveal that his agreement to 'act' for her was nothing more than a ruse to enable him to cover up for his own misconduct in relation to Mr Andrews and his family. Mr Williamson, in essence, conspired with a person subject to a FVRO (Mr Mitchell) to purport to act on behalf of the person protected by the restraining order, in order to have that person cancel the restraining order. In return for Mr Williamson agreeing to betray his own 'client' (Ms Brooks), Mr Mitchell in turn agreed to support Mr Williamson in his lies to the Board in relation to the complaint by Mr Andrews' family. 89 That conduct was nothing short of treacherous. The protection of the public requires that it be denounced in the strongest possible terms. I certify that the preceding paragraphs comprise the reasons for decision of the Supreme Court of Western Australia. JN Principal Associate to the Hon Chief Justice Quinlan 21 AUGUST 2026 -- 19 of 19 --