The Solicitors Act 1974 s.37A and Sch.1A was applicable to the period before a complaint against a solicitor was made to the Office of Supervision of Solicitors and the period after the complaint had been made, and it was possible in principle for a finding of inadequate professional services to be based on a solicitor's conduct after the office had become involved. However, it was important that the solicitor's conduct of his defence in the course of an investigation by the office should not be assessed by the standards applicable, in accordance with the Guide to the Professional Conduct of Solicitors, to the solicitor's internal complaints handling procedure.

[2005] EWHC 1570 (Admin)

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