REIMAGINING LEGAL PRACTICE IN NIGERIA BEYOND RULE 7 OF THE RULES OF PROFESSIONAL CONDUCT(RPC): ETHICAL EXPANSION AND SOCIO-ECONOMIC IMPERATIVES

BY

AFAM OKEKE*

Abstract

This paper reimagines the scope of legal practice in Nigeria in response to numerous rulings by the Legal Practitioners Disciplinary Committee (LPDC) that continue to prohibit legal practitioners from engaging in non-legal commercial activities simultaneously. It reassesses the justification of these rulings based on the interpretation of Rule 7 of the Rules of Professional Conduct to evaluate their ongoing relevance amidst Nigeria’s socio-economic realities. Using a doctrinal and comparative research approach, the study examines developments in the United Kingdom, Canada, and South Africa, where multidisciplinary and ethically supervised models have developed. The paper explores how various regulatory philosophies impact the balance between ethical discipline and professional flexibility. The key finding indicates that a strict and literal interpretation of professional ethics could unintentionally act as a structural barrier, hindering the progressive evolution of legal practice. This rigidity may restrict the flexibility necessary for ethical adaptation to modern economic conditions and limit the profession’s capacity to participate in emerging interdisciplinary and innovation-driven spaces essential for economic sustainability. It recommends a context-specific interpretation of Rule 7 of the RPC that permits ethically supervised multidisciplinary practice in alignment with Nigeria’s socio-economic realities.

Key words: Legal Ethics; Professional Regulation; Ethical Expansion; Socio-Economic Sustainability.

• INTRODUCTION

The legal profession in Nigeria has historically been governed by a conservative ethical framework designed to preserve its independence, integrity, and the public’s confidence in the justice system. A central pillar of this framework is Rule 7 of the Rules of Professional Conduct for Legal Practitioners (RPC), which prohibits lawyers from engaging in any business or trade outside the practice of law, except as passive shareholders or directors. This prohibition reflects a long-standing philosophy that legal practice should remain a noble and undiluted calling, free from commercial conflicts that could compromise ethical judgment.[1]

In Nigeria’s fast-changing socio-economic landscape, this rule’s inflexibility has become more debated. As the economy broadens, professional roles now often overlap with fields like technology, finance, governance, and project management. Nonetheless, the Legal Practitioners Disciplinary Committee (LPDC) continues to enforce a strict interpretation of Rule 7, penalising lawyers involved in or overseeing non-legal business activities. Cases such as Legal Practitioners Disciplinary Committee v. Gbenoba [2]and LPDC v. Fawehinmi[3] exemplify this conservative approach to prioritise ethical standards over adaptability in the profession. Although these rulings are rooted in the preservation of professional dignity, they raise critical questions about whether Nigeria’s regulatory framework adequately accommodates modern professional realities. Udemezue argues that ethical standards must remain dynamic to ensure that the law retains both moral and practical relevance. In an economy characterised by fluctuating markets and limited professional opportunities, the absolute restriction imposed by Rule 7 may hinder legitimate diversification, constrain innovation, and ultimately threaten lawyers’ economic sustainability.[4]

Comparative experiences from other jurisdictions illustrate that ethical regulation and professional flexibility can coexist. In the United Kingdom, the Legal Services Act 2007 introduced Alternative Business Structures (ABS), permitting multidisciplinary partnerships between lawyers and non-lawyers under regulated ethical supervision.[5] Similarly, in Canada, reforms in provinces such as Ontario and British Columbia encourage innovation within legal services while maintaining professional accountability.[6] South Africa’s Legal Practice Act 28 of 2014 also demonstrates a pragmatic regulatory approach that seeks to balance ethics with inclusivity and transformation.[7]

This paper adopts a doctrinal and comparative approach to assess whether Nigeria’s restrictive ethical regime continues to serve the profession’s best interests. It examines how alternative regulatory philosophies in other jurisdictions manage the tension between professional discipline and adaptability. The paper ultimately argues that without a context-sensitive reappraisal of Rule 7 and related LPDC jurisprudence, Nigerian legal practice risks stagnation in an increasingly interdisciplinary and innovation-driven global environment. A regulatory recalibration that reconciles ethical integrity with socio-economic realities is therefore essential to ensuring that Nigerian lawyers remain ethically grounded yet economically sustainable in a rapidly transforming world.

The paper is structured into five sections. Following this introduction, Section 2 examines the ethical boundaries of legal practice in Nigeria, analysing the philosophy and intent of Rule 7 of the Rules of Professional Conduct and the implications of its current interpretation. Section 3 interrogates the judicial and disciplinary construction of the phrase “trade or business”, highlighting how this interpretation has produced economic and professional consequences for legal practitioners. Section 4 offers comparative insights from other jurisdictions and proposes pathways toward ethical expansion of legal practice in Nigeria. Section 5 concludes the paper and presents recommendations.

2. Ethical Boundaries of Legal Practice in Nigeria

The ethical boundaries of legal practice in Nigeria are anchored on a long-standing commitment to uphold professional integrity, independence, and fidelity to public interest. The Nigerian Bar, from its colonial roots, adopted the common law tradition, which views the legal profession as a distinct and honourable calling, requiring its members to avoid any engagement likely to compromise their impartiality or erode public confidence in justice administration. [8] Over the years, this moral philosophy has been codified through successive instruments of professional regulation, culminating in the Legal Practitioners Act[9] and the  Rules of Professional Conduct for Legal Practitioners 2023 (RPC 2023)[10]. Under these regimes, the Legal Practitioners Disciplinary Committee (LPDC) emerged as the institutional guardian of professional ethics, mandated to enforce compliance with the Rules of Professional Conduct (RPC) issued by the Bar Council. [11]

2.1 Rule 7 of the Rules of Professional Conduct 2023 and its underlying philosophies

Rule 7 of the Rules of Professional Conduct for Legal Practitioners 2023 prohibits a lawyer from engaging in “any trade, business, or profession” outside legal practice, subject to narrow exceptions such as acting as a shareholder, investor, or director without involvement in the management of the business.[12] The emphasis on “any” reflects deliberate breadth, signalling an intention to cast a wide regulatory net rather than target specific industries. The rule is therefore framed as exclusionary by default, permissive only by exception, a drafting choice that prioritises professional containment over commercial flexibility. [13]

The phrase “trade, business or profession” is particularly instructive. Its cumulative structure suggests legislative intent to cover not only profit-driven commercial ventures such as trade and business, but also structured skilled engagements like profession, even where such engagements may align with legal expertise, e.g., tax consultancy, compliance advisory, company secretarial services, or project supervision.[14] The lack of qualifiers such as “unethical”, “unrelated”, or “conflicting” means the prohibition is not contingent on proving harm, conflict, or disrepute, but is pre-emptive, operating on the assumption that dual commercial participation inherently threatens professional sanctity.[15]

This interpretation shows that the essence of the rule lies in protecting the ethical foundations of legal practice. It aims to ensure that a lawyer’s loyalty to the client remains undivided, free from the influence of outside commercial interests, and that professional judgment is not compromised by competing personal or financial considerations[16]. In doing so, it reinforces public trust in the profession. The rule ultimately reflects a traditional fiduciary understanding of legal practice, presenting the lawyer not as a commercial actor in a competitive marketplace, but as a guardian of public confidence whose role requires independence, integrity, and disciplined ethical conduct.[17]

Viewed through a purposive lens, Rule 7 advances three key normative objectives: it operates protectively by shielding clients from divided loyalty and ensuring that financial interests do not interfere with legal judgment.[18]It functions by preserving the profession’s historical identity as a learned vocation rather than a commercial enterprise[19], and it acts preventively by curbing potential reputational, regulatory, and conflict-of-interest risks before they arise.[20]

However, when examined against contemporary realities, tensions emerge between the letter and the applicational consequences of the rule. The wording does not distinguish between incompatible dual engagements that may harm clients and complementary interdisciplinary roles that enhance legal service delivery without ethical compromise.[21] For example, activities such as legal-tech innovation, consultancy in regulated industries, policy design, corporate training, or real estate project advisory could fall within the textual prohibition despite presenting minimal or no risk to professional integrity.[22]

Furthermore, the assumption that non-legal commercial participation necessarily erodes ethical judgment may reflect historical caution more than present-day professional ecosystems, where regulated multidisciplinary practice operates successfully in jurisdictions such as the UK, Canada, and South Africa under structured ethical compliance and not a blanket exclusion.[23]

Accordingly, while the spirit of the rule is ethically defensible, its wording creates interpretive rigidity that may inadvertently foreclose progressive professional evolution rather than merely regulate it. The challenge, therefore, is not the rule’s protective philosophy, but its binary framing, which restricts the possibility of calibrated participation even where ethical safeguards exist to mitigate risk.[24]

3. Judicial and Disciplinary Interpretation of “Trade or Business”

The Supreme Court and the LPDC have consistently upheld a restrictive reading of “trade or business.” In NBA v. Ibebunjo, the Committee held that a lawyer who engaged in buying and selling land while practising law was guilty of professional misconduct.[25]Similarly, in Incorporated Trustees of Nigeria Bar Association v. Charles (2004), a practitioner acting as a property manager was sanctioned for violating Rule 7, as property management was deemed a commercial occupation incompatible with legal practice. A lawyer was accused of mismanaging his client’s properties and failing to account for the ₦16,000,000 in rent that was collected during nine years from 2006 to 2015. According to the Rules of Professional Conduct for Legal Practitioners, 2023 (“RPC”), the lawyer was prosecuted for: (i) failing to provide accounts for the rent money; (ii) misappropriating the rent for personal use; and (iii) collecting a 10% management fee as a lawyer. He refuted these accusations, stating that he kept accurate records, served as a brother rather than in a professional position, and sent the rent after deducting his 10% management fee for services rendered. The LPDC investigated whether the Complainant and the Respondent had a client-lawyer relationship. The LPDC concluded that there is a client-lawyer relationship based on the Respondent’s admission to the Nigeria Police, in which he acknowledged being debriefed by the Complainant as Property Manager. According to the respondent, no professional expenses were paid in order to create this kind of relationship. The LPDC, however, disregarded this claim and made it clear that pro bono legal services are possible. The presence of a professional relationship was further supported by the Respondent’s admission that they collected a 10% charge from the rent. The LPDC also considered the possibility of a lawyer serving as a property manager. It concluded that because these positions are incompatible with the legal profession, solicitors cannot work as estate agents, property managers, project sor commission agents. The LPDC concluded that the Respondent was guilty of infamous conduct for accepting the position of Property Manager, in violation of Rule 7(2) of the RPC and punishable under section 12(1) of the Legal Practitioners Act[26], even though it did not find enough evidence of misappropriation or failure to render accounts. As a result, LPDC suspended the Respondent from practising law for two years in compliance with section 12(1) of the LPA.[27]

The reasoning behind these decisions rests on the preservation of professional dignity and independence. The LPDC, therefore, equates involvement in business ventures, however tangential, with ethical compromise.

However, this traditional reasoning has become increasingly untenable in the 21st century, where the boundaries between law, business, and technology are porous. The more recent LPDC ruling in October 2023 on project supervision, which held that supervising construction or infrastructural projects falls within the prohibited “trade” category, reflects the same conservative ethos.[28] Yet, it raises a critical question: when such supervision involves legal compliance, due diligence, or contract administration, activities fundamentally legal in nature, should it still be deemed unethical?

3.1 Economic and Professional Consequences

The cumulative effect of the restrictive interpretation of Rule 7 has been exacerbated by the increasing encroachment of non-lawyers into sectors traditionally regarded as within the core professional remit of legal practitioners. For instance, company registration, which was once the exclusive domain of lawyers under the Companies and Allied Matters Act 1990 (CAMA), has been largely automated through the Corporate Affairs Commission (CAC) portal, enabling non-lawyers to perform incorporation services.[29] Conveyancing and land transactions, historically reserved for lawyers, are now frequently handled by estate agents, surveyors, and other intermediaries. This marginalisation is partly self-inflicted, as the legal profession has failed to redefine its boundaries in response to evolving socio-economic conditions.[30]

While ethical purity remains important, the reality is that economic survival has also been argued to constitute ethical consideration in itself.  The ability of lawyers to sustain their livelihoods through legitimate means contributes to the stability and integrity of the profession. Thus, the historical trajectory of legal restriction, while rooted in noble intentions, has produced unintended ethical and economic distortions.

4. Comparative Insights and Pathways Toward Ethical Expansion

Comparative experience demonstrates that jurisdictions that have moved to accommodate multidisciplinary practice and innovation have not achieved this by weakening ethics; rather, their regulatory frameworks treat ethics as a supervisory mechanism for participation in non-legal commercial environments. This insight is crucial to the argument advanced in this paper that Nigeria does not need to choose between professional integrity and participation in the modern economy; it can pursue ethical expansion by regulating risk instead of prohibiting activity.

4.1 Comparative Models

Comparative developments across common-law jurisdictions reveal two competing regulatory ideologies concerning the lawyer’s engagement with commerce:

1. The protectionist model: This is where ethics is used to insulate the profession from market forces, as is the case in Nigeria.
2. The supervisory model: This is where ethics is used to manage market participation while preserving independence, as is the case in the United Kingdom, Canada, and South Africa.

The clearest contrast appears when comparing Nigeria’s restrictive interpretation of Rule 7 with the risk-managed innovation frameworks adopted in the United Kingdom. The Legal Services Act 2007 marked a fundamental shift away from monopoly-style legal provision by establishing Alternative Business Structures (ABS), enabling non-lawyers to co-own or manage legal service entities.[31] Section 72 defines Alternative Business Structures (ABS) as firms where non-lawyers may manage or hold ownership interest in legal services entities. Whereas sections 83 establish the licensing regime, empowering regulators to authorise ABS and impose conditions to mitigate ethical risks and Schedule 11 mandates non-lawyer owners to submit to professional conduct rules. Instead of assuming that commercial involvement compromises professional integrity, the ABS model recognises that risk exists and must be managed, not forbidden. Firms are required to implement conflict-management systems, appoint compliance officers for legal practice, and show governance arrangements that uphold independent legal judgment.[32] Regulations issued by the Solicitors Regulation Authority further impose duties of transparency, ownership disclosure, and accountability to ensure legal decisions remain free from commercial pressure.[33]A demonstrable positive outcome of the reform is seen in the case of Co-operative Legal Services Ltd v Phillips & Ors where the Court of Appeal upheld the ability of a non-lawyer-owned ABS to recover legal costs in litigation, confirming ABS as full legal service providers, not second-tier participants.[34] Further empirical evidence from the Legal Services Board (LSB) shows that ABS firms are 20% more likely to implement compliance systems than traditional firms, exhibit faster adoption of legal technology, and expand access to underserved markets (e.g., low-cost family law services).[35] Thus, ABS have not diluted professional ethics; rather, structural supervision has increased compliance and consumer access.

Canada applies similar principles through Multi-Disciplinary Practice (MDP) regimes, albeit with stricter requirements for lawyer control. Under By-Law 7 of the Law Society of Ontario, lawyers may partner with non-lawyers provided that lawyers retain “effective control” over the provision of legal services and remain professionally responsible for all legal work within the entity.[36] The Law Society of British Columbia’s MDP rules impose structural separation: non-lawyer partners may not interfere with legal work, and the partnership must maintain policies that protect confidentiality, privilege, and undivided loyalty to clients.[37] The Federation of Law Societies of Canada reinforces this by codifying that lawyers remain ethically accountable for all legal services rendered within such collaborative structures. [38] This was the position in the case of Merchant Law  Group v. Canada (Revenue Agency),[39] where the Court of Appeal held that solicitor-client privilege extends to business partners within an MDP insofar as lawyers retain control of legal services. The case confirms that multidisciplinary partnerships do not compromise confidentiality where regulatory safeguards exist.

South Africa illustrates a transition model. The Legal Practice Act 28 of 2014 established a unified regulatory body and opened up for multidisciplinary affiliations, enabling lawyers to participate in adjacent sectors such as compliance, corporate governance, and regulatory advisory, provided that lawyers retain control over legal work and ethical accountability.[40] The Legal Practice Council’s implementing rules expressly require that multidisciplinary participation must not violate independence, confidentiality, or conflict-of-interest standards.[41] In effect, South Africa recognises that lawyers’ value is enhanced and not reduced when paired with financial, commercial, or technical expertise.[42]

Across these jurisdictions, three common principles are evident:

1. Independence is the protected value, not exclusivity: Regulatory frameworks do not protect lawyers from competition; they protect clients from compromised legal advice.
2. Ethics operates as risk management and not prohibition: Regulatory design centres on structures (conflict systems, ownership controls) rather than categorical bans.
3. Interdisciplinary participation expands access and relevance: Legal work increasingly intersects with other disciplines (tax, technology, finance, compliance). Effective regulation facilitates these interactions, instead of obstructing them.

Nigeria’s Rule 7 framework stands alone as a relic of the insulation philosophy, rooted in colonial-era conservative professional norms that assumed exposure to commerce equals ethical compromise.

• Comparative Insights Applied to Nigeria: A Framework for Ethical Expansion

Rule 7 of the RPC 2023 restricts simultaneous engagement in legal practice and “any other trade or business.” The Legal Practitioners Disciplinary Committee (LPDC) has historically interpreted this as a blanket prohibition, collapsing the distinction between economic participation and ethical compromise. The textual focus, however, is on dual practice where another trade is actively carried on in a manner that interferes with legal practice. There is no textual basis to prohibit passive shareholding; owning or founding companies where lawyers do not manage day-to-day operations; participation in legally adjacent sectors (compliance, governance, legal tech) or multidisciplinary collaboration within structures controlled by lawyers. The barrier, then, lies in interpretation, not regulation.

Dana Remus’s work provides the philosophical scaffolding for Nigeria’s reform. In Reconstructing Professionalism, Remus critiques global market reforms that reduce legal practice to a commodified business transaction, arguing that the lawyer’s value lies in non-market attributes like independent judgment, trust, loyalty, empowerment of the client, and public-regarding service.[43] She warns that when law is treated merely as a market commodity, market logic displaces ethical reasoning, exposing legal work to efficiency pressures that can erode judgment and loyalty. Yet, Remus does not call for isolation of the profession. Rather, she advocates a third regulatory paradigm, where the profession “harnesses market forces in productive ways, rather than being controlled by them in deleterious ways.” [44] Which brings us to the conclusion that it is not engagement with commerce that threatens ethical identity but the lack of governance structures around each engagement. Applying Remus’s insight to Nigeria suggests that reform should occur through ethical expansion, not deregulation.

Nigeria’s current interpretation of Rule 7 has produced unintended and counterproductive consequences. By enforcing a restrictive prohibition on lawyers’ participation in non-legal commercial activity, the profession has ceded traditional legal-adjacent markets such as company incorporation, conveyancing, property documentation, and routine compliance work to non-lawyers. Simultaneously, lawyers remain largely absent in emerging interdisciplinary markets such as legal technology, regulatory compliance, corporate governance, and innovation-focused advisory sectors, where legal expertise should give them a natural advantage. In response to economic realities, some practitioners resort to informal, unregulated, or concealed commercial partnerships, increasing the likelihood of conflicts of interest, confidentiality breaches, and ethical violations. In effect, over-protection has created the very ethical risk the regulation was meant to prevent, revealing the paradox inherent in the current approach.

Comparative regulatory experiences demonstrate that ethical safeguards are most effective when they supervise and structure commercial engagement rather than prohibit it. Across jurisdictions, reforms that permit multidisciplinary participation, while embedding accountability, conflict-management mechanisms, and governance structures, have managed to preserve the fiduciary core of legal practice and enhance the profession’s relevance in evolving markets. In the United Kingdom, the Legal Services Board’s post-implementation review of Alternative Business Structures shows that ABS firms consistently exhibit stronger internal governance and are significantly more likely to implement formal compliance and technology systems compared to traditional law firms.[45] The study found that ABS entities were early adopters of digital platforms and online service tools, particularly in consumer-facing areas such as family law and estate planning, suggesting that structural flexibility encourages innovation without diminishing ethical accountability. These experiences show that ethics should guide participation rather than eliminate it. Professional independence is preserved not by isolating lawyers from commercial environments, but by ensuring that lawyers remain in control of legal work and ethical decision-making within those environments. This approach enables lawyers to participate meaningfully in emerging interdisciplinary sectors without sacrificing the principles that distinguish law as a profession grounded in trust, loyalty, and confidentiality.

From this perspective, Rule 7 of the RPC 2023 does not require abolition; it requires reinterpretation. A modern, purposive approach should recognise that regulated multidisciplinary participation is both legitimate and ethically sustainable. The objective of regulation should be to include lawyers in developing professional and commercial arenas while ensuring that fundamental ethical obligations such as independence, secrecy, loyalty, and conflict avoidance are preserved, diligently monitored, and enforceable.

5 Recommendations and Conclusion

The analysis of Nigeria’s current regulatory posture under Rule 7 of the Rules of Professional Conduct 2023, juxtaposed with comparative insights from the United Kingdom, Canada, and South Africa, demonstrates that the prohibitionist model governing dual practice is neither inevitable nor normatively superior. While Rule 7 is rooted in legitimate concerns preserving independence, preventing conflicts of interest, and maintaining public confidence in the legal profession, the strict and literal interpretation applied by the Legal Practitioners Disciplinary Committee (LPDC) has produced outcomes that are economically limiting and ethically counterproductive. The section, therefore, proposes a framework for ethical expansion anchored on reinterpretation, structured supervision, and regulatory innovation, rather than deregulation.

The comparative study shows that the legal professions in other jurisdictions developed by abandoning the assumption that commercial involvement inherently compromises professional judgment. Instead, reforms aim to maintain independence through governance, conflict resolution, and a clear division of legal and non-legal roles. As Dana Remus states, the real danger to professionalism is not market involvement but the dilution of core values such as judgment, loyalty, confidentiality, and client empowerment, particularly when market forces are left to operate freely. The UK, Canada, and South Africa demonstrate that these values can be upheld within modern practice frameworks through mechanisms like designated legal compliance officers (UK ABS model), lawyer-control clauses (Canadian MDP framework) and statutory supervision by a unified regulatory authority (South Africa LPC).

Nigeria, by contrast, assumes that avoidance is a better safeguard than supervision, thereby freezing the profession at a historical point that no longer aligns with global practice realities. The failure to adapt has not shielded lawyers from market forces; instead, it has caused them to lose ground to non-lawyers in traditional and emerging markets. Lawyers are now absent from multidisciplinary and innovation-driven fields such as legal technology, ESG governance, data protection compliance, and corporate regulatory advisory and fields that integrate legal knowledge with commercial and technical expertise.

5.2 Recommendations for Ethical Expansion

To reposition the profession for relevance in an evolving economy, this paper recommends a three-tier reform model that preserves ethical obligations while permitting commercial participation:

1. A reinterpretation rather than an amendment to Rule 7 of the RPC 2023: The LPDC should adopt a purposive approach that differentiates between the dual practice of law and a trade that undermines legal judgment, as well as multidisciplinary participation where lawyers maintain control over legal services. A strict interpretation of Rule 7 should only be applied when concurrent commercial involvement affects independence or undivided loyalty.
2. Introduction of a supervised multidisciplinary participation regime: Nigeria should establish a regulatory framework similar to the ABS and MDP regimes, requiring mandatory disclosure of non-legal business interests, structural separation between legal and commercial functions, written conflict-of-interest protocols, and retention of legal decision-making authority by lawyers.

This mirrors the governance-focused approach seen in the UK and Canada, where non-lawyer involvement is permitted but regulated, not prohibited. ²⁷

• Creation of an institutional compliance framework within the NBA and LPDC:

A compliance reporting framework similar to the designated Compliance Officer in the UK should be implemented. Firms involved in multidisciplinary activities should be required to submit annual disclosures of ownership and governance structures, as practised under the Legal Services Act 2007. ²⁸ This approach mitigates ethical risks without restricting legitimate economic activity.

5.3 Conclusion

The main conclusion of this research is that a strict and literal interpretation of Rule 7 of the RPC 2023 has become a structural obstacle to the development of legal practice in Nigeria. Comparative evidence shows that ethical supervision is more effective than outright prohibition and that independence is maintained through proper governance rather than isolation. An ethically broadened model of practice would enable lawyers to regain traditional markets and explore new interdisciplinary areas while keeping the fiduciary principles of the profession.

Accordingly, Rule 7 does not need to be abolished. It needs to be reinterpreted through a contemporary, purposive lens that acknowledges the legitimacy of multidisciplinary participation and aligns the Nigerian legal profession with global practice realities. Ethical integrity and economic sustainability are not competing imperatives. They are mutually reinforcing when regulation focuses on preserving the conditions of professionalism rather than restricting the opportunities for professional relevance.

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[1] Udemezue, S.C., ‘An Appraisal of Professional Legal Ethics and Proper Conduct for Lawyers in Nigeria’ (2021) Vol. 21, No 17, Legal Ethics and Professional Responsibility Journal

<https://hq.ssrn.com/Journals/IssueProof.cfm?abstractid=3842835&journalid=205108&issue_number=17&volume=21> accessed 5 November 2025

[2] Legal Practitioners Disciplinary Committee v. Gbenoba (2015) 17 NWLR (Pt. 1488) 485.

[3] Legal Practitioners Disciplinary Committee v. Fawehinmi (1985) 2 NWLR (Pt. 7) 300.

[4] Udemezue, S.C. (n.1).

[5] Sanderson, P., ‘Reimagining Legal Practice: Multidisciplinary Models and the Legal Services Act 2007’ (2018) Modern Law Review Vol. 81, No. 4, 622–645.

[6] Adams, T., and Lahey, K., ‘Innovation and Regulation in Canadian Legal Practice’ (2019) Canadian Bar Review Vol. 97, No. 2, 347–368.

[7] Moseneke, D., ‘Transformation and the Legal Profession in South Africa: Balancing Ethics and Access’ (2015) South African Law Journal Vol. 132, No. 1, 1–22.

[8] Elias, T.O., The Nigerian Legal System (London: Routledge, 1963) 45.

[9] LPA Cap. L11, Laws of the Federation of Nigeria 2004.

[10] Rules of Professional Conduct for Legal Practitioners 2023, Extraordinary Federal Republic of Nigeria Official Gazette No. 103, Vol. 110, Government Notice No. 69 (6 June 2023) https://gazettes.africa/akn/ng/officialGazette/government-gazette/2023-06-06/103/eng%402023-06-06/source.

[11] LPA 2004 S.12(4)

[12] RPC  2023 r 7(1).

[13] Ibid.

[14] Okoli P & Ezike C, ‘Reconceptualising the Regulation of Legal Practice in Nigeria’ (2022) Nigerian Bar Journal 45(3) 67.

[15] Ibid.

[16]Udemezue, (n.1).

[17] T.A. Aguda, Practice and Procedure in the Supreme Court of Nigeria (Heinemann, 1980) 112.

[18] Udemuzue, (n.1).

[19] Aguda (n17).

[20] Okoli & Ezike (14).

[21] A. Oba, ‘The Changing Roles of Lawyers in a Market-Driven Legal Ecosystem’ (2023) Nigerian Law and Practice Review 12(1) 23.

[22] Ibid.

[23] S. Pope, ‘Multidisciplinary Practices and the Future of Legal Regulation’ (2021).

[24] Oba (n.21).

[25] (2013) 18 NWLR (Pt 1386) 413 LPDC.

[26] LPA 2004, S 12(1).

[27] Ibid.

[28] LPDC Direction given on the 9^th Day of October 2023 in Petition No. BB/LPDC/401/2021.

[29] Ezenagu, K., “Technology, Deregulation and the Changing Face of Legal Practice in Nigeria,” Nigerian Law Journal Vol. 18 (2021), 75–93; Companies and Allied Matters Act (CAMA) 2020, s. 33(1).

[30] Udemezue, Sylvester & Shaeeb, Olajumoke. (2022). Delimiting Lawyers’ Involvement in Sale of Land in Light of the Steady Diminution of the Law Practice Space in Nigeria. 3. 183.

[31]Legal Services Act 2007 (UK), c. 29

[32] Legal Services Board (UK), Guidance on Regulatory Objectives and Risk-Based Supervision (2011),< https://www.legalservicesboard.org.uk/wp-content/media/Guidance_on_Regulatory_Objectives.pdf > accessed 7 November 2025

[33] Solicitors Regulation Authority (UK), Alternative Business Structures  Licensing and Requirements, <https://www.sra.org.uk/solicitors/resources/abs/ > accessed 7 November 2025

[34] [2014] EWCA Civ 87.

[35] Legal Services Board (UK), Evaluation: Market Impact of ABS Reforms (2018).

[36] Law Society of Ontario, By-Law 7, Business Entities (MDPs), < https://lso.ca/about-lso/legislation-rules/by-laws/by-law-7-business-entities > accessed 7 November 2025

[37] Law Society of British Columbia, Law Society Rules, Part 2, Division 2: Multi-Disciplinary Practices, < https://www.lawsociety.bc.ca/support-and-resources-for-lawyers/act-rules-and-code/> accessed 7 November 2025

[38] Federation of Law Societies of Canada, Model Code of Professional Conduct (2017), < https://flsc.ca/resources/model-code-of-professional-conduct/ > accessed 7  November 2025

[39] 2010 FCA 184.

[40] Legal Practice Act 28 of 2014 (South Africa), Government Gazette No. 38022 (22 May 2014), <https://www.gov.za/documents/legal-practice-act > accessed 7 November 2025

[41] Legal Practice Council (South Africa), Rules for Legal Practitioners, Candidate Attorneys and Juristic Entities (2018), Government Gazette No. 41879, <https://lpc.org.za/rules/ > accessed 7 November 2025

 

[43] Dana A Remus, Reconstructing Professionalism (2017) 51 Georgia Law Review 1229.

[44] Ibid.

[45] Ibid (n.35).