ROLE OF SENIOR ADVOCATE AND RESTRICTIONS
IMPOSED ON THEM IN ADVOCATES ACT ,1961 IN THE
SUPREME COURT OF INDIAN RULES
Nancy Girdher
A3221515049
B.com LLB Section A
9th SEM
1
I. INTRODUCTION
A lawyer is "a person learned in the law; as an attorney, counsel or solicitor; a
person licensed to practice law." The profession of law is called a noble profession. It
does not remain noble merely by calling it as such unless there is a continued,
corresponding and expected performance of a noble profession. Its nobility has to be
preserved, protected and promoted. An institution cannot survive in its name or on its
past glory alone. The glory and greatness of an institution depends on its continued and
meaningful performance with grace and dignity. The profession of law being noble and
honorable one, it has to continue its meaningful, useful and purposeful performance
inspired by and keeping in view the high and rich traditions consistent with its grace,
dignity, utility and prestige. The legal profession and lawyers being an integral part of
society fulfilling a dire and pressing need must therefore be regulated and bound by rules
and ethics which bind their profession and practice.
Hence the provisions of the Advocates Act and Rules made there under inter alia aimed
at to achieve the same ought to be given effect to in their true spirit and letter to maintain
clean and efficient Bar in the country to serve cause of justice which again is noble one.
An advocate shall, at all times, comport himself in a manner befitting his status as an
officer of the Court, a privileged member of the community, and a gentleman, bearing in
mind that what may be lawful and moral for a person who is not a member of the Bar, or
for a member of the Bar in his non-professional capacity may still be improper for an
Advocate. The Bar Council has framed specific rules in this regarding putting restriction
on senior advocates and on to take up other employments by the Advocates.
The main objective of the project is to analyze about restriction on senior advocates , as a
legal practioner, while he is on the roll of a high court, is not entitled to enter into any
business or service without permission of the court. If he does, disciplinary action may
taken against such person.
2
Senior advocates, that they shall in the matter of law as mentioned in the section 30 of
the Advocate Act, subjected to the restriction under the powers provided under Rule 16
(3) and 49 (1) (g) of Act and Part VI of Bar Council of India Rules deals with the Rule
governing Advocates that, deals with the Restrictions imposed on Senior Advocates that
they shall not file a Vakalatnama or act in any Court, or Tribunal, or before any person or
other authority, shall not appear without an Advocate on Record in the Supreme Court or
without an Advocate in Part II of the State Roll in any court, or tribunal, or before any
person or other authorities, shall not accept instructions to draft pleading or affidavits,
advice on evidence or to do any drafting work of an analogous kind in any Court or
Tribunal, shall not accept directly from a client any brief or instructions to appear in any
Court or Tribunal ,who had acted as an Advocate (Junior) in a case, shall not after he has
been designated as a Senior Advocate advise on grounds of appeal in a Court of Appeal
or in the Supreme Court, except with an advocate as aforesaid. A Senior Advocate may in
recognition for rendering his service as an advocate for appearing in any matter should
get paid fee which he thinks is considerable
The analyze also give a clear view about the other advocates restricted to take up other
employments provided under Rules 47 to 52 of Section VII of the Bar Council of India
rules deals with restrictions on other employments. This restriction is considered as a
general etiquette on the part of lawyers as the profession of law is a noble profession and
requires full time dedication such as, shall not personally engage in any business, shall
not be a managing director, shall not be a full-time employee of any person, Government,
firm, corporation, or concern and on taking up such employment and the test, therefore, is
not whether such person is engaged on terms of salary or by payment of remuneration,
but whether he is engaged to act or plead on its behalf in a court of law as an advocate.,
and an advocate who has inherited, or succeeded by survivorship to a family business
may continue it, but may not personally participate in the management thereof.
It states that nothing in these rules shall prevent an advocate from accepting after
obtaining the consent of the State Bar Council, part-time employment provided that in the
opinion of the State Bar Council, the nature of the employment does not conflict with his
professional work and is not inconsistent with the dignity of the profession. Thus shall be
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subject to such directives if any as may be issued by the Bar Council India from time to
time i.e. shall intimate such fact to the Bar Council concerned and shall cease to practice
as long as he is in such employment
II. SENIOR ADVOCATE
There are two types of advocates Senior advocate and other Advocate . Earlier, the rules
mandated that three senior advocates designated by Delhi High Court, with not less than
five years individual standing at the Bar, have ability and special knowledge, as senior
advocate, may jointly make a proposal to the High Court for designation of an advocate
as a senior advocate . The suo moto initiation by court has remain unchanged .
The amended Rule 7(B), however, will allow an advocate to apply for senior advocate
designation himself or herself.
“Any advocate who fulfils the eligibility conditions prescribed herein before may submit
a written application for being designated as Senior Advocate to the Registrar General”
RESTRICTION ON SENIOR ADVOCATES
Under the Advocates Act 1961, the Bar Council of India may impose certain
restrictions on practice by Senior Advocates it is thought necessary in the interests
of the legal profession. Senior Advocates shall, in the matter of their practice of the
profession of law mentioned in Section 30 of the Act, be subject to the following
restrictions1:
(a) A Senior Advocate shall not file a Vakalatnama or act in any Court, or Tribunal, or
before any person or other authority mentioned in Section 30 of the Act.
1
J.P.S.Sirohi, Professional Ethics, Accountability for Lawyers and Bench-Bar Relations, edition, 2002,
Allahabad Law Agency., pg no.409
4
“To Act” means to file an appearance or any pleading or application in any court,
to Tribunal or before any person or other authority mentioned in Section 30 of the Act, or
to do any act other than pleading required or authorized by law to be done by a party in
such Court, or Tribunal, or before any person or other authority mentioned in the said
Section either in person or by his recognized agent or by an advocate or an attorney on
his behalf .However, examining or cross-examining witnesses is not cobered by the term
"acting" and hence, senior counsels are not restrained from carrying out the same.
(b) (i) A senior Advocate shall not appear without an Advocate on Record in the
Supreme Court or without an Advocate in Part II of the State Roll in any court, or
tribunal, or before any person or other authorities mentioned in Section 30 of the Act.
(ii) Where a Senior Advocate has been engaged prior to the coming into force
of the Rule in this Chapter, he shall not continue thereafter unless an Advocate in Part II
of the State Roll is engaged along with him. Provided that a Senior Advocate may
continue to appear without an Advocate in Part II of the State Roll in cases in which he
had been briefed to appear for the prosecution or the defense in a criminal case, if he was
so briefed before he is designated as a Senior Advocate or before coming into operation
of the rules in this Chapter as the case may be.
Advocate on Record, is an advocate who has passed a qualifying examination
conducted by the Supreme Court. The examination is taken by an advocate who has been
enrolled with a Bar Council for at least five years and has completed one year’s training
with an AOR of not less than five years standing, so that the senior advocate shall not be
appear without him.
(c) He shall not accept instructions to draft pleading or affidavits, advice on evidence or
to do any drafting work of an analogous kind in any Court or Tribunal, or before any
person or other authority mentioned in Section 30 of the Act or undertake conveyancing
work of any kind whatsoever. This restriction however shall not extend to settling any
such matter as aforesaid in consultation with an Advocate in Part II of the State Roll.
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(cc) A Senior Advocate shall, however, be free to make concessions or give undertakings
in the course of arguments on behalf of his clients on instructions from the junior
Advocate.
Senior Advocates are designated as such by the Supreme Court of India or by any
High Court. The Court can designate any advocate, with his consent, as Senior Advocate
if in its opinion by virtue of his ability and standing at the Bar or special knowledge or
experience in law, the said advocate is deserving of such distinction. He is also not
entitled to accept instructions to draw pleadings or affidavits, advise on evidence or do
any drafting work of an analogous kind in any court or tribunal in India or undertake
conveyancing work of any kind whatsoever.
(d) He shall not accept directly from a client any brief or instructions to appear in any
Court or Tribunal, of before any person or other authority in India.
(e) A Senior Advocate who had acted as an Advocate (Junior) in a case, shall not after
he has been designated as a Senior Advocate advise on grounds of appeal in a Court of
Appeal or in the Supreme Court, except with an advocate as aforesaid.
This prohibition shall not extend to settling any such matter as aforesaid in
consultation with a junior.
(f) A Senior Advocate may in recognition of the services rendered by an Advocate in
Part II of the State Roll appearing in any matter pay him a fee, which he considers
reasonable.
III. CASE STUDY –
Ram Sagar Shukla v. U.P. Textile Printing Corporation Ltd.2
Fact:
It appears that the Writ Petition No. 7937 of 1985. Ram Sagar Shukla v. U.P. Textile
Printing Corporation Ltd. Khalilabad, Basti and Ors., was dismissed in default on
2
AIR 2004 All 209
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16.7.2003 and restoration application has been filed by Sri K. P. Agrawal designated
Senior Advocate on 14.8.2003 and this Court has passed the order dated 18.8.2003 which
reads as below :
'List this case before me on 21.8.2003. A notice has to be issued to Sri K. P. Agrawal,
Senior Advocate to indicate under what circumstance he has filed this application, being
a Senior Advocate he is not supposed to file any application and he is not supposed to file
Vakalatnama by his signature as the Full Court of Allahabad High Court has designated
him as Senior Advocate. If satisfactory explanation is not given by him the case shall be
referred to Hon'ble the Chief Justice for consideration for removal of his senior's counsel
designation and the matter shall be sent to Bar Council of U. P. and Registrar General
shall intimate to Sri K. P. Agrawal about this order with an intimation to this Court.'
The affidavit enclosed with the restoration application was sworn by Sri NazmeHasan
claims to be the registered clerk of Sri K. P. Agrawal, Senior Advocate. It has been
contended in paragraph 3 that when the case was listed on 16.7.2003 at serial No. 4 at
page 121 the name of Sri K. P. Agrawal, Sri B. C. Tripathi and Sri Hari Om Khare were
shown as counsel for the petitioner. Since the name of other than Sri K. P. Agrawal was
shown it was presumed that the petitioner had engaged the other two counsel and he was
not present when the case was called out, however, it was not noted in the office of Sri K.
P. Agrawal, Senior Advocate and Sri K. P. Agrawal has no knowledge that the case was
listed otherwise he certainly might have appeared before the Court and might have
argued the case. As contended in the affidavit that at the time of filing the Writ Petition
No. 7937 of 1985 in the name and signature of Sri K. P. Agrawal, he was not a
designated Senior Advocate. It has further been contended in paragraph 4 of affidavit that
it was not on account of any negligence but for bona fide reasons the case was dismissed
in default. No satisfactory explanation however has been given in this application besides
the important aspect that despite designated as Senior Advocate Sri K. P. Agrawal has
filed the application in derogation to the applicable provisions after being designated as
Senior Advocate he could not be engaged as counsel for any party on Vakalatnama3.
3
http://indiankanoon.org/doc/1902098/(accessed on 16/8/13)
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Now in the present facts and circumstances, the following questions arise :
(i) Whether Senior Advocate could be engaged by client on Vakalatnama
(ii) Whether a Senior Advocate could directly receive instruction from the client/ party?
(iii) Whether the present application of restoration could be filed for and on behalf of
Senior Advocate and on the signature of Senior advocate?
For dealing these aspects it is necessary to deal the relevant provisions of the Advocates
Act and the Bar Council of India Rules and other different provisions applicable in the
present case.
30. Right of advocates to practice.--Subject to provisions of this Act, every advocate
whose name is entered in the (State roll) shall be entitled as of right to practice
throughout the territories to which this Act extends,--
(i) in all courts including the Supreme Court ;
(ii) before any Tribunal or person legally authorized to take evidence ; and
(iii) before any other authority or person before whom such advocate is by or under any
law for the time being in force entitled to practice4.
Chapter VI deals with Miscellaneous parts of 'Act' and Section 49 deals with General
power of the Bar Council of India to make rules and the relevant part is provided as
below : Section 49(1)(g) : The restrictions in the matter of practice to which senior
advocates shall be subject : Under the powers provided under Rule 16 (3) and 49 (1) (g)
of Act and Part VI of Bar Council of India Rules deals with the rule governing advocates
and Chapter I deals with the Restrictions on Senior Advocates.
Held:
Only an advocate having at least 20 years of practice can be recommended :Provided that
a retired Judge of any High Court who is qualified to practice in the Allahabad High
4
https://www.google.co.in/search?q=restrictions+on+senior+advocates&newwindow=1&ei=waUPUtXxA4
mOrQeU4YDoDw&start=10&sa=N&biw=1024&bih=667
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Court may also be recommended for being designated as Senior Advocate :Provided
further that it shall be open to the Court to relax the qualification in an exceptional case.
(ii) The recommendation shall be accompanied by a written consent and bio-data of the
person recommended to be designated as Senior Advocate. -The recommendation shall
be screened by a Committee comprising of five senior most Judges of the Court at
Allahabad and two senior most Judges of the Court at Lucknow, and if it is not
disapproved by the Committee, it shall be placed by the Chief Justice before the Full
Court for consideration and approval through secret ballot. 7. In these circumstances, it
was not in consonance to the provisions of 'Act' as well as provisions of Bar Council of
India Rules that Senior Advocate Sri K.
In these circumstances, it was not in consonance to the provisions of 'Act' as well as
provisions of Bar Council of India Rules that Senior Advocate Sri K. P. Agrawal signed
the restoration application and got the affidavit sworn by a clerk attached to him. The
conduct of Sri K. P. Agrawal, designated Senior Advocate is unbecoming of Senior
Advocate and here all his conduct and projection is unlike a Senior Advocate. It was not
necessary to file restoration application by his own signature as after the designation as
Senior Advocate, he is not supposed to file Vakalatnama of any client and is not
supposed to file any application in his own handwriting. A senior counsel is ceased to be
counsel for the purpose of filing pleadings, representing and engagement by a client. The
petitioner might have engaged some other counsel or the earlier counsel might have filed
the restoration application only or application or submissions could only be settled by a
Senior Advocate. In the present facts and circumstances, this application cannot be
treated to be duly filed, therefore, it is difficult to accept the justification and explanation
given in the supporting affidavit. Therefore, it is not necessary to go into the contents and
justification of the restoration application and in these circumstances, it is only indicated
that Sri K. P. Agrawal was to maintain and uphold the dignity of Senior Advocate in the
present facts and circumstances.
For dealing the restoration application this Court referred and relied on the order passed
in Restoration Application No. 138670 of 2003 in W. P. No. 28709 of 1993 that if Sri K.
P. Agrawal was earlier a junior counsel and was engaged by a client after designated as
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Senior Advocate he ceased to be counsel for the party and he cannot say that since earlier
he was not senior counsel, therefore, he has legal right to file restoration application in
his signature. For the reasons recorded in the order dated 18.12.2003 passed in
Restoration Application No. 138670 of 2003 in Writ Petition No. 28709 of 1993, the
restoration application is rejected.
V.G. Tamaskar vs High Court of Chhattisgarh & Others5
Fact:
The petitioner is an advocate practicing in the High Court of Chhattisgarh and has a
background of public service. He has filed this writ petition praying for quashing the
designation of respondents 5 to 21 as Senior Advocates of this Court and for directing the
High Court of Chhattisgarh to designate all those lawyers who had applied to be
designated as Senior Advocates by issuing appropriate writ of certiorari / mandamus. The
petitioner has also prayed for directing the High Court of Chhattisgarh to frame separate
rules for designating the lawyers as Senior Advocates by issuing appropriate writ of
mandamus.
The petitioner who has appeared in person submitted that a Full Bench of the Allahabad
High Court has held in the case of Democratic Bar Association vs. High Court of
Judicature at Allahabad6, writ petition filed by Association of Advocates and the
Advocates practicing in the High Court of Allahabad questioning the legality of the rules
for designation of Senior Advocates was maintainable. He submitted that in view of the
said decision of the Full Bench of the Allahabad High Court, the present writ petition by
which designation of Senior Advocates of this Court has been challenged, is maintainable
at the instance of the petitioner. With no doubt in our mind that an Advocate of this Court
has the locus standi to file a writ petition challenging the decision of the High Court to
designate a Senior Advocate. In the case of S.P. Gupta vs. President of India7, the
Supreme Court has held that practicing lawyers have vital interest in the maintenance of a
fearless and an independent judiciary to ensure fair and fearless justice to the litigants and
5
AIR 2006 Chh 153
6
2001 (5) SLR 88
7
AIR 1982 SC 149
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can challenge a circular issued by the Law Minister with regard to the short term
extensions of the sitting Additional Judges of High Courts and such practicing lawyers
either in their individual capacity or representing Lawyers' Association have not merely
sufficient interest but special interest of their own in the subject matter of the writ
petition. Similarly, practicing lawyers of the High Court of Chhattisgarh have sufficient
interest in the subject matter of the present writ petition namely, designation of Senior
Advocates of the High Court of Chhattisgarh and we cannot dismiss the present writ
petition at the threshold on the ground that a practicing advocate does not have any locus
standi to file a writ petition challenging the designation of Senior Advocate by the High
Court. But we make it clear that when a challenge is made by a practicing Advocate to
the designation of the Senior Advocate by the Court, the Court will not interfere with the
decision of the High Court to designate an Advocate as Senior Advocate except on well
settled principles of judicial review.
Mr. V.G. Tamaskar next submitted that the High Court of Madhya has framed the rules in
exercise of its powers under Section 34(1) read with Section 16(2) of the Advocates Act,
1961 laying down therein the procedure for designation of Senior Advocates as well as
the manner in which the applications will be filed by an Advocate for designating him as
a Senior Advocate and the manner in which such applications will be dealt with, but the
aforesaid Rules framed by the High Court of Madhya Pradesh have not been followed by
the High Court of Chhattisgarh while designating the respondents 5 to 21 as Senior
Advocates of this Court. Mr. Tamaskar vehemently submitted that if respondents 5 to 21
have not been designated in accordance with the provisions of the rules framed by High
Court of Madhya Pradesh, then their designation as Senior Advocates is invalid. He
submitted that till the rules for designation of Senior Advocate are framed by the
Chhattisgarh High Court, the rules framed by High Court of Madhya Pradesh are in force
and have to be applied by the High Court of Chhattisgarh.
The Full Court of High Court of Chhattisgarh has formed opinion in its meeting held on
09.01.2002 and in its Meeting held on 06.01.2005 that the Advocates named in the said
resolutions be designated as Senior Advocates under Section 16 (2) of the Advocates Act,
1961. Unless, the said opinion is shown to be vitiated by mala fide or extraneous
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considerations, this Court in exercise of its powers under Article 226 of the Constitution
will not interfere with the same. In the present case, the petitioner has not made any
allegation that mala fide or extraneous consideration has influenced the Full Court of
High Court of Chhattisgarh to designate respondents 5 to 21 as Senior Advocates. We are
thus not in a position to interfere with the same.
Mr. Tamaskar submitted that it be clear from the document in Annexure P-16, annexed to
the writ petition that he applied on 07.02.2005 to the Registrar General of High Court of
Chhattisgarh for furnishing certified copies of the proceedings of the Full Court of the
High Court in its meetings convened after 01.11.2000 for designating Advocates
practicing in the High Court of Chhattisgarh as Senior Advocates but no such certified
copy was made available to him. It be clear from the bare language of the Section 76 of
Indian Evidence Act, 1872 that a public document which any person has a right to inspect
can only be given to such person applying for a certified copy. Nothing has been brought
to our notice to show that the petitioner in the present case has a right to inspect the
resolutions of the Full Court of High Court of Chhattisgarh convened after 01.11.2000 for
designating Senior Advocates practicing in the High Court of Chhattisgarh.
Held:
Henceforth the designation or non-designation of an Advocate as Senior Advocate by the
High Court of Chhattisgarh is transparent, it be appropriate if the High Court frames
guidelines for designation of an Advocate as Senior Advocate and notifies the same to all
concerned including the Advocates practicing in the High Court and District Courts as
has been done in other High Courts. Therefore, direct respondent No.1 to frame
guidelines for designation of an Advocate as Senior Advocate keeping in mind the
provision of Section 16(2) of the Advocates Act, 1961.
Hence disposed, writ petition with a direction to respondent No.1 to frame, within two
months from today, guidelines for designation of Advocates as Senior Advocates and
thereafter consider the pending applications of the Advocates for designation of Senior
Advocates in accordance with such guidelines. Also direct that the respondent No. 1 to
ensure that Advocates those who have been designated as Senior Advocates including
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respondents 5 to 21 do not file any Vakalatnama in this Court and their names do not
appear in the cause list, as per the restrictions imposed by the Bar Council of India under
Section 16(3) and 49 (1) (g) of the Advocates Act, 1961.
IV. CONCLUSION & SUGGESTIONS
The paper draws conclusions based on the preceding chapters. The cardinal
principle which determines the privileges and responsibilities of advocate in relation to
the court is that he is an officer to justice and friend of the court and restricted to the rules
laid. This is the primary position. A conduct therefore which is unworthy of him as an
officer of justice cannot be justified by stating that he did it as the agent of his client. His
status as an officer of justice does not mean he is subordinate to the judge. It only means
that he is an integral part of the machinery for the administration of justice. An advocate
is the most accountable, privileged and erudite person of the society and his act are role
model for the society, which are necessary to be regulated. The advocate must not place
himself in a position which he cannot effectively discharge his obligations to the Court as
minister of justice. He should not have any personal interest in the litigation he is
conducting. Advocates in their professional capacity address each other as brothers. This
spirit of fraternity at Bar is one of the noblest traditions of the legal profession and is
many centuries old.
Senior Advocates are designated as such by the Supreme Court of India or by any High
Court. The Court can designate any advocate, with his consent, as Senior Advocate if in
its opinion by virtue of his ability and standing at the Bar or special knowledge or
experience in law, the said advocate is deserving of such distinction. A Senior Advocate
is not entitled to appear without an Advocate-on-Record in the Supreme Court or without
a junior in any other court or tribunal in India. He is also not entitled to accept
instructions to draw pleadings or affidavits, advise on evidence or do any drafting work
of an analogous kind in any court or tribunal in India or undertake conveyancing work of
any kind whatsoever, but this prohibition shall not extend to settling any such matter as
aforesaid in consultation with a junior.
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As far as the senior advocate is concerned, it is professional malpractice that he is
indulging in by accepting briefs. And the State Bar Council is the authority that regulates
it. But the problem is proving that it is happening. And remember the State Bar Council is
usually loaded in favor of a Senior Advocate who has over time proved his standing at
the bar vis a vis an upstart junior lawyer. And not to forget an enmity with him could
harm you in the long run. As far as payment is concerned, unless you have a written
agreement there is little you can do. Paying a junior engaged in his chambers is more
moral than legal without a contract. Nothing quite as exhilarating as being your own boss.
The role of the lawyers in the society is of great importance. They being part of the
system of delivering justice holds great reverence and respect in the society. Each
individual has a well-defined code of conduct which needs to be followed by the person
living in the society.so a legal practitioners, therefore at every given opportunity seek to
enlighten and educate ourselves on the contents of these rules as we strive for a better
legal profession and also all carry out our expected duties as practitioners and resolve to
co-operate sincerely with ourselves. Honesty and honorable dealing are, of course,
expected from every man, whether he is engaged in professional practice or in any other
gainful occupation. But in a profession, pecuniary success is not the only goal. Service is
the ideal, and the earning of remuneration must always be subservient to this main
purpose.
So it is suggested in the phrase ‘practice of law’ under Rule 2(xx) is very wide and
includes giving of legal advice and contemplates a degree of independence and neutrality
in the legal advice given and does not appear to include legal advice given by in-house
counsel (that is, a salaried employee of a Company etc.) to their employer. Thus, in-
house counsel cannot be considered to be into ‘practice of law’ or a ‘legal professional
legal adviser’ within the meaning of section 129 of the Evidence act. Nor, are they
advocates within the meaning of Section 2(a) of the Act of 1961.
In case an advocate take up full time employment, he must inform the bar council on
whose roll his name is entered and must cease to practice as an advocate for the duration
of his employment. In case an advocate wants to take up part time work, he may do so
with the consent of the state bar council, which must be satisfied that such work, will not
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conflict with his professional work, and is not inconsistent with the dignity of the
profession.
BIBLIOGRAPHY
BOOKS REFERRED –
SanjeevRao, Indian Advocates Act, 1971.
J.P.S.Sirohi, Professional Ethics, Accountability for Lawyers and Bench-Bar
Relations, edition, 2002, Allahabad Law Agency., pg no.409
Krishna Murthy Iyer’s Book on Advocacy.
Journal of Bar Council of India.
Ramantha Aiyer, Legal and Professional Ethics, 3 ed, 2003, Wadhwa& Co, Nagpur
SandipBhalla, Advocates Act 1961 and Professional Ethics,2 ed, 2004, Nasik Law
house
Prof. KailashRai, Legal Ethics, Accountability for Lawyers and Bench-Bar Relations,
8 ed, 2013, Central Law Publications, Allahabad., pg no.89
WEBSITE REFERRED-
http://www.lawweb.in/2013/05/other-professional-can-not-be-granted.html
www.legalserviceindia.com/
http://rdalegal.wordpress.com/2013/02/27/honble-supreme-court-of-india-considers-
public-prosecutors-to-be-eligible-for-district-judiciary-posts-clarifies-the-restrictions-
under-rule-49-of-the-bci-rules/
https://www.google.co.in/search?q=restrictions+on+senior+advocates&newwindow=
1&ei=waUPUtXxA4mOrQeU4YDoDw&start=10&sa=N&biw=1024&bih=667
http://indiankanoon.org/doc/1902098/
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