Is It Time to Abolish (Or Reform) the Good Character Requirement?

My last Slaw column discussed two recent cases in which Ontario’s Law Society Tribunal found individuals who had previously engaged in sexual misconduct involving minors were currently “of good character”. The findings in those cases, AA and Colangelo, have since been (repeatedly) upheld on appeal.[1]

Unsurprisingly, these decisions were controversial in the court of public opinion (sample Toronto Star comment: “When your [sic] a member of a governing body that characterizes pedophiles as people ‘of good character’, you have a problem”). Lawyers and law students similarly expressed dismay with the outcomes (for example, one commenter on my last post stated, “I feel ashamed to be a lawyer when I think that someone who sexually assaulted his own kids and was dishonest with the regulator in an official application is now presumptively as trusted as me”).

But the fact that these decisions were unanimously upheld in each of the Law Society Tribunal Appeal Panel, Divisional Court, and Ontario Court of Appeal strongly suggests that they were sound judgments—according to the established standard.

Are these cases illustrations of the old adage “bad facts make bad law”? Or could it be that the well-established test for demonstrating one’s good character is not fit for purpose?

This column considers the meaning of “good character” and the objectives of the good character requirement. I posit that while the good character requirement (now) serves a laudable purpose, its purpose is not—and perhaps cannot be—realized in its application. As such, I question whether the costs of the good character requirement may be greater than its value, and assess if there is a better approach.

What is the good character requirement?

Section 27(2) of Ontario’s Law Society Act provides that it is a requirement for the issuance of a license to practice law “that the applicant be of good character”. This requirement is also provided for in s. 8(1) of the Law Society’s By-Law 4. (Although this column refers to the requirements in my home jurisdiction of Ontario, all jurisdictions in Canada impose some version of the good character requirement as a prerequisite for licensing).

Neither the Act nor the LSO By-Laws define what it means to “be of good character”. The following definitions are regularly cited in the Ontario case law:

Character has been defined as:

that combination of qualities or features distinguishing one person from another. Good character connotes moral or ethical strength, distinguishable as an amalgam of virtuous attributes or traits which undoubtedly include, among others, integrity, candour, empathy and honesty.

…

“[G]ood character” means those qualities which might reasonably be considered in the eyes of reasonable men and women to be relevant to the practice of law…Character…comprises…at least these qualities:

1. 1. An appreciation of the difference between right and wrong;

   2. The moral fibre to do that which is right, no matter how uncomfortable the doing may be and not to do that which is wrong no matter what the consequences may be to oneself;

   3. A belief that the law at least so far as it forbids things which are malum in se must be upheld and the courage to see that it is upheld.[2]

I am not the first to suggest that this definition of “good character” is unhelpfully vague and leaves significant room for interpretation (and potentially bias). It has rightly been noted that the good character requirement “raises serious concerns about unpredictability, inconsistency, and vagueness”.[3]

The case law is similarly of little assistance; each case is decided on its facts, and will consider not only the nature of the past misconduct but also, among other things, whether the applicant has rehabilitated and credibly demonstrated remorse.

In the result, applicants like AA who have admitted to serious misconduct can be admitted to the profession, where others who committed less serious errors, such as minimizing the nature of an academic offence on their licensing application, can be denied.

Why do law societies have a good character requirement? (then and now)

There is a good and meaningful reason to impose a good character requirement today—even though, historically, its purpose was questionable.

The late Deborah Rhode, a leading American legal ethics scholar, wrote about the historical use of character requirements in the legal profession to screen out applicants who were deemed to be morally or socially undesirable, including on the basis of sex, class, ethnicity, and religion. She noted that in the nineteenth century women were categorically excluded from legal practice on character grounds, with one court noting that “the peculiar qualities of womanhood, its gentle graces, its quick sensibility, its tender susceptibility, its purity, its delicacy, its emotional impulses, its subordination of hard reason to sympathetic feeling” rendered women unqualified to be lawyers.[4]

Into the twentieth century, an American Bar Association campaign for higher professional standards excluded candidates deemed “ill-prepared” and “morally weak”—who often just happened to be Jewish or from immigrant families. And in the eight years following the 1928 implementation of a character requirement in Pennsylvania, through which candidates could be assessed as “unworthy”, the proportion of Jews admitted to the bar dropped sixteen percent, and almost no Black lawyers were admitted.[5]

The Americans were likely not the sole perpetrators of this discrimination masquerading as moral authority. W. Wesley Pue has described early Canadian good character assessments as being oriented towards ensuring that only those who met certain cultural ideals could join the legal profession, with an eye to identifying “what sort of person from what sort of background could properly embody law in a new British dominion”.[6]

There is no evidence that today’s good character requirements are intended to exclude marginalized groups, nor that they have that effect.[7] Indeed, as described further below, very few applicants are ultimately denied entry to the profession on character grounds (although it is unclear how many otherwise well-qualified individuals may be deterred from seeking to become lawyers in the first place).

But the historical use of character requirements for improper purposes serves to highlight the vagueness and subjectivity of the standard, and raises a serious question of what qualifies law societies to cast judgment on applicants’ moral fitness.

Today, the Law Society of Ontario’s website provides:

The good character requirement is intended to protect the public and maintain high ethical standards in the professions by ensuring that persons who are licensed as lawyers and paralegals show respect for the rule of law and the administration of justice and conduct themselves with honesty, integrity and candour.

The Law Society Tribunal regularly cites the following definition from Lawyers & Ethics: Professional Responsibility and Discipline:

The purposes of the good character requirement are the same as the purposes of professional discipline: to protect the public, to maintain high ethical standards, to maintain public confidence in the legal profession and its ability to regulate itself, and to deal fairly with persons whose livelihood and reputation are affected.[8]

These stated objectives are compelling and laudable. It makes perfect sense that in a regulated profession that is premised on trust, a regulator will seek to assure to the public that lawyers who have earned the privilege of licensing are worthy of that trust. As Gavin MacKenzie has stated:

The requirement that applicants be of good character is preventative, not punitive. It recognizes that character is the well-spring of professional conduct in lawyers. By requiring lawyers to be of good character, law societies protect the public and the reputation of the profession from potential lawyers who lack the fundamental quality of any person who seeks to practise as a member of the legal profession, namely, integrity.[9]

Does the good character requirement actually serve its laudable purpose?

The problem, however, is that there is no basis to suggest that one’s misconduct prior to being licensed to practice is in any way predictive of their conduct in practice.[10]

In fact, the (admittedly limited) evidence suggests the contrary. A 2013 study of individuals admitted to the Connecticut bar over a three-year period found that there was no statistically significant correlation between pre-application criminal convictions or academic misconduct and future discipline. (Interestingly, two statistically significant predictors of future misconduct were traffic tickets, which are specifically excluded from disclosure requirements in Ontario, and gender, with men being 3.5 times more likely to be subject to discipline than women.)[11]

The Law Society of Ontario even appears to acknowledge this problem; in a 2013 submission to the Federation of Law Societies of Canada, it stated: “The Law Society agrees that there is little evidence that past misconduct is a meaningful predictor of future behaviour, particularly as it relates to future professional misconduct.”[12]

The LSO continued to state, however, that “it is of the view that there are other reasons to continue the requirement”, noting:

It is important to convey to the public and the profession that licensees are required to comply with standards of professional conduct. One of the ways of doing so is to license those who, at the time of licensing, have demonstrated … respect for the rule of law and the administration of justice, honesty, governability and financial responsibility. Underlying these behaviours is the principle that the profession must be worthy of clients’ and the public’s trust. If an applicant’s past conduct has raised some question about his or her respect for the behaviours integral to the profession, it is valuable for law societies to make further inquiries and determine whether the applicant should be licensed. In this way, the Law Society’s commitment to maintaining standards of professional conduct is demonstrated.[13]

While this seems to make sense at first blush, I suggest, with respect, that it is not a particularly strong justification for maintaining the good character requirement. If we accept that past misconduct does not pose a greater risk of professional misconduct to the public, what exactly makes it “valuable” for law societies to investigate those applicants to determine whether they should be licensed, but not others (who by all accounts pose the same risk to the public)?

I am left with the uneasy sense that the good character requirement may be little more than theatre or, as some may call it, “virtue signalling”: it is an attempt to show the public that past bad actors are subject to scrutiny before they will be licensed—despite our understanding that this scrutiny does not as a practical matter protect the public from any enhanced risk.

Now, it may be argued that even if the good character requirement does not protect the public from any risk of future misconduct, it protects public confidence in the legal profession. Perhaps there is value in appearing to assure the public that they can trust lawyers, even if those assurances are of little or no substantive value. Maybe not every policy choice must be evidence-based, if the objective is simply to make the public feel they can trust the profession.

I might agree with that position if the costs of the good character requirement were minimal. But that is not the case.

How do we assess “good character”?

For many licensing applicants, the good character requirement is a breeze. When I submitted my own licensing application in my third year of law school, I was in the fortunate position to not have to think twice about it; I simply checked “no” to all the screening questions I was asked and, having failed to raise any “red flags”, I was be presumed to be of good character. (We’ll return to this presumption in a moment.)

But this is not the case for everyone—and a good character investigation, with or without a good character hearing, can impose significant costs on applicants.

If you answer “yes” to any of the Law Society’s screening questions, the LSO will request particulars and supporting documentation.

The screening questions are broad. An applicant must disclose, for example, whether they have been “convicted of any offence under any statute in Canada or elsewhere” or “disciplined by an employer in Canada or elsewhere”.[14] Frankly, I question the connection between being worthy of the public’s trust to practice of law and, for example, getting a ticket for forgetting to tap one’s Presto card on the streetcar or receiving demerits for showing up late for a couple shifts as a teenage barista (I have asked, and the LSO maintained that there is no exclusion for employment discipline in one’s youth).

I have no doubt that applicants making those disclosures would be deemed to be “of good character” after a few exchanges with the LSO. But, in my experience, it can still take months to clear a candidate even where that outcome is obvious to me—and during that time applicants are left anxious and fearful that that their license will be delayed or denied.

In other cases, a good character investigation can be quite intense, with many rounds of records requests and interviews (of not only the applicant but also their friends, family, and colleagues who serve as references). These interviews can involve highly personal questions, which candidates have little power to decline to answer. More than one of my clients have expressed that aspects of the process felt “invasive”.

This is particularly so when the matter that gave rise to the good character investigation was a result of past mental health challenges. In a compelling article entitled “The trauma of proving my good character”, Toronto litigator Naomi Sayers described how the LSO’s good character investigation process required her to revisit two exploitative situations from her past; the guilt she felt requiring her family to do the same; and how she needed to return to counselling as a direct result of the investigation dredging up matters she had hoped were behind her.

A good character investigation can also delay one’s call to the bar, potentially for years. And if an applicant retains counsel to assist them with the process (which is generally advisable), they must also incur legal costs at a time when they are not yet capable of earning an income as a lawyer and likely facing significant student debt.

Most good character investigations are ultimately closed after the Law Society satisfies itself that the applicant’s past conduct does not bring their good character into question. If it is not satisfied, the matter proceeds to a hearing, where a hearing panel of the Law Society Tribunal will decide whether the applicant is of good character. An applicant cannot be refused a license without a hearing.[15]

To determine whether an applicant is of good character, the hearing panel will consider what are known as the “Armstrong factors”: the nature and duration of the past misconduct; the applicant’s remorse; their successful rehabilitative efforts; their conduct since their misconduct; and the passage of time since their misconduct.[16]

I do not take issue with these factors per se—as far as a legal test for proving one’s good character after prior misconduct goes, these factors are as good as any.

But I do question the idea that Law Society benchers or a Tribunal can or ought to judge a person’s integrity, empathy, and moral fibre through an adversarial hearing process.

Rather, I agree with the suggestion made by Professor (now Justice) Alice Woolley in her 2013 article “Can Good Character Be Made Better?”: the good character requirement does not adequately consider the nuances of human behaviour, but rather is premised on “the childish belief that the world neatly divides into good guys and bad guys, and that a regulatory hearing can identify the difference”.[17]

Before moving on, I briefly return to my concern with the presumption of good character granted to most licensing applicants.

Those of us who breezed through the good character questionnaire should not assume it is because we are morally superior to those caught by the screening process. As Justice Woolley notes, there is a vast “array of psychological research indicating that a significant majority of people will not do the right thing when the circumstances are unfavourable to right-thing doing”.[18]

Put another way, perhaps I was presumed to be of good character not because I have “the moral fibre to do that which is right, no matter how uncomfortable the doing may be, and not to do that which is wrong, no matter what the consequences may be to oneself”, but because I was privileged to have rarely found myself in circumstances that were “unfavourable to right-thing doing”.

We have all made mistakes and errors in judgment. But some of us are presumed to have “moral and ethical strength” regardless, while others must subject themselves to moral scrutiny or prove their honesty and integrity before they can be called to the bar.

How many people fail to satisfy the good character requirement?

Only a small handful of good character matters proceed to a hearing. In her article, Justice Woolley observed:

In Ontario, between 2006-2012, 575 applications raised issues of character. From those applications, however, only 24 hearings have been held and only 2 applicants have been denied admission… This number is comparable to the pre-2006 period in Ontario where from 1989 to 2005 five applicants were denied admission.[19]

I sought to update Justice Woolley’s numbers in preparing this article. Based on my review of Law Society Tribunal decisions on CanLII, I determined that 24 good character hearings (for new lawyer licensing applicants) were decided between 2013-2024, resulting in six candidates being denied entry to the profession.[20]

Putting Justice Woolley’s numbers and mine together, it appears that in total the Law Society of Ontario has rejected just 13 lawyer applicants on the basis that they were not “of good character”.[21] (In Ontario, no applicants were denied admission to the bar as a result of good character hearings before 1989.[22]) For reference, there are currently approximately 59,000 lawyers in Ontario, and approximately 2,500 lawyers are licensed each year.[23]

Incidentally, the six cases I reviewed in which the applicants were found not to be of good character were not those that featured the most serious past misconduct. During the same period, candidates with past criminal convictions for manslaughter, terrorism offences, child pornography, and child luring were found to be of good character, having credibly demonstrated remorse for their past misconduct and their successful rehabilitation.

The six candidates who were denied licensing on character grounds since 2013 were, however, all found to have deliberately misled the LSO in connection with the licensing process.

While dishonesty (or lack of candour) is certainly tied to the concept of “good character”, these cases need not to have been determined on the basis that they were not “of good character”; a different section of the LSO’s Licensing By-Law independently provides that an applicant who makes a false or misleading representation in connection with their licensing application will be automatically disqualified from licensing.[24]

In other words: even if past misconduct were predictive of future misconduct, the good character requirement would be doing little or nothing to keep past bad actors out of the profession.

The problem with “good character”

To summarize, so far I’ve argued that:

• The definition of “good character” is vague and vulnerable to subjective interpretation, raising serious concerns of inconsistency and unpredictability;
• It’s entirely unclear how the good character requirement actually protects the public, as the evidence suggests that pre-licensing misconduct is not predictive of post-licensing professional misconduct;
• The good character process imposes significant financial, emotional, and time costs on candidates who must endure an investigation (and this is to say nothing about how much of the LSO’s budget must be expended on these lengthy investigations and hearings!);
• It is questionable whether a panel of benchers can—or ought to—judge a person’s integrity, empathy, and moral fibre through an adversarial hearing process.
• Only 13 lawyer licensing candidates in Ontario have ever been denied entry to the profession on the basis that they were found not to be of good character; and
• Media reports and public comments suggest that when candidates who previously committed serious misconduct are granted a license (after being found to have rehabilitated and to be of good character), public confidence in the legal profession may be diminished.[25]

Put simply, the good character requirement imposes significant costs for minimal (if any) benefit.

So what are the alternatives?

Justice Woolley argued that the most justifiable approach would be to abandon the good character requirement altogether, because it is premised “on irrational beliefs about the nature of human behaviour and a concern with the reputation of the profession that is difficult to justify”. She adds that there are significant advantages to abandoning the requirement, including that it would “protect applicants from arbitrary results and allow regulatory resources to be re-deployed to more effective and useful initiatives”.[26]

Professor Rhode similarly described character requirements for licensing as a “fundamentally illegitimate” and stated that “preserving the pretense of character certification may simply buttress the profession’s claims to social status, economic monopoly, and regulatory autonomy, while deflecting attention from more meaningful forms of oversight”.[27]

Justice Woolley acknowledged, however, that elimination of the requirement is unrealistic, noting that “even if a strong empirical case against character and fitness regulation can be made, the public or media may still harshly criticize the legal profession for admitting someone with a serious or troubling criminal record”.[28]

I agree that elimination of the good character requirement is highly unlikely. And as noted above I accept that there is some value, in a self-regulated profession based on trust, in sending a message to the public that the privilege of a licence to practice law will not be granted to someone who has shown themselves to be unworthy of that trust.

The challenge, of course, lies in what criteria are used to separate the trustworthy from the untrustworthy.

Seeing as this is more about protecting lawyers’ reputation in the eyes of the public than protecting the public from practical harm, I suggest that bright lines are preferable to a fuzzy, subjective, case-by-case approach.

Predictability and certainty are valuable not only to applicants (who are investing tens of thousands of dollars and years of their lives to obtain the academic qualifications to practice law), but also to the public, who should be able to understand when and on what basis someone will be deemed to be “of good character”.

Right now, the good character questionnaire casts a very wide net, then the LSO relies on the subjective application of the Armstrong factors to pass judgment on those caught in the net.

I propose a more objective, predictable, and tailored approach.

At least in part, good character disclosure should mirror that which licensees must disclose to the Law Society. Section 2 of LSO By-Law 8 requires licensees to report any charges of

• an indictable offence under the Criminal Code;
• an offence under the Controlled Drugs and Substances Act; or
• an offence under any other legislation where the charge alleges, explicitly or implicitly, dishonesty on the part of the licensee or relates in any way to the professional business of the licensee.

These are much more closely tailored to a risk of professional misconduct and the purpose of the good character requirement: promoting public trust in lawyers’ honesty, respect for the rule of law, and professional practice. (The framing could be adapted to include equivalent offences in jurisdictions other than Canada.)

Other issues that raise questions about a person’s honesty, governability, and financial management may also warrant disclosure and scrutiny, such as if an applicant:

• has received sanctions for academic dishonesty;
• has been disciplined in another regulated profession;
• has been deemed a vexatious litigant or held in contempt of court; or
• is an undischarged bankrupt.

Rather than embark on a multi-factorial subjective assessment of the “character” of a person who makes any of the above-noted disclosures, law societies should consider associating clear consequences with these clear criteria.

It would be open to law societies to permanently bar from the profession persons who committed certain particularly serious and stigmatized offences—such as sexual abuse of a child or first-degree murder—on the basis that many members of the public consider such offences to be unforgivable and fundamentally incompatible with the trust granted to a lawyer, and as such a wholesale ban is necessary to protect public confidence in the legal profession.

In most cases, however, law societies could preclude those who meet the stated criteria from entering the profession for a specified, time-limited period—for example, until at least five years has passed since the offence and the completion of any applicable sanctions. They could also impose additional licensing requirements after this waiting period, such as completion of additional ethics and professionalism training; an additional period of supervision by senior counsel; requiring a co-signer on a trust account; or other risk-based licence conditions.

Temporary or permanent prohibitions on licensing could be either absolute or presumptive. Discretionary exemptions based on mitigating circumstances surrounding the original misconduct may be warranted in exceptional cases, provided this does not turn into a loophole to return to the norm of passing moral judgment on a case-by-case basis. I expect exemptions would be sought only rarely, as in most cases it would be more practical for a prospective applicant to keep their nose clean and “wait it out” rather than fight to reduce a post-sanction waiting period.

This approach would suffer from the same lack of empirical justification as the current one. But it would ensure the predictability and consistency of the good character requirement, while still accounting for the possibility and value of rehabilitation. (That rehabilitation would be assumed from the passage of time without further misconduct rather than factually assessed based on an applicant’s personal journey may be an imperfect approach, but I suggest it is preferable to the unpredictable and resource-intensive status quo that ultimately turns in large part on how a candidate presents to a law society panel).

The proposed approach would strike a reasonable balance between sending a clear message to the public that the privilege of practising law is not available to those who violate legal norms and acknowledging that people who have made mistakes can change and earn back trust that has been lost.

I do not believe this would “open the floodgates” or lower our profession’s standards. As illustrated above, the good character requirement precludes remarkably few candidates from practising law. Most applicants whose pasts raise a question of their good character ultimately demonstrate through the passage of time and their conduct since the misconduct that they have gained insight and rehabilitated.

Unfortunately, there is reason not to be optimistic about reform—the “waiting period” proposed above is not new, but rather is consistent with an idea proposed by Deborah Rhode in her above-noted Yale Law Journal article from 1985.[29]

Of note, Justice Woolley’s article referred to above was written in 2013 in the context of a Federation of Law Societies of Canada consultation into good character reform—which, based on what I can decipher from the dearth of information about it online, appears to have fizzled out without resulting in any concrete recommendations for change.

It seems to me that good character requirements may be something of a regulatory hot potato: clearly flawed in principle; primarily affecting those with little power to effect change; and invoking such strong value judgments (and potential for public outcry) that reform seems not to be worth the hassle.

One hopes that, in a profession “devoted to the preservation of principles and the protection of the rights of the unpopular”,[30] our regulators may soon have the courage to consider reform anyway.

_________________________

[1] See Law Society of Ontario v. Colangelo, 2024 ONSC 2446, aff’d 2025 ONCA 341; Law Society of Ontario v. A.A., 2024 ONSC 5971. I understand the AA matter is pending (another) appeal at the Ontario Court of Appeal, but has not yet been heard at the time of writing. I am aware of two other good character cases involving individuals with previous convictions for sexual offences involving minors, both of whom were found to be of good character and licensed to practice law.

[2] LSUC v Armstrong, 2011 ONLSAP 1 at paras 12, 16.

[3] See, e.g., Gavin MacKenzie, Lawyers & Ethics: Professional Responsibility and Discipline, loose-leaf, (Toronto: Thomson Reuters Canada Limited, 1993–), p. 23-6 [Lawyers & Ethics].

[4] Rhode, Deborah L., “Moral Character as a Professional Credential”. The Yale Law Journal, Vol. 94:3 (1985), 491-603 [Rhode], citing In re Goodell, 39 Wis. 232, 245 (1875).

[5] Rhode, pp 501-2.

[6] W Wesley Pue, “Cultural Projects and Structural Transformation in the Canadian Legal Profession” in W Wesley Pue & David Sugarman, eds, Lawyers and Vampires: Cultural Histories of Legal Professions (Oxford: Hart Publishing, 2003) 331. My thanks to one of the students in my 2025 Legal Ethics seminar at Osgoode Hall Law School for drawing my attention to this resource.

[7] Which is not to say that the good character requirement does not or cannot have that effect—but I have no basis upon which to assert that it does exclude marginalized groups. If any readers have more information on this point of which I am unaware, I’d be grateful to hear from you.

[8] Lawyers & Ethics, p. 23-2.

[9] Ibid, p. 23-3.

[10] Indeed, although Mr. MacKenzie states that its purpose is “preventative”, he also questions whether “the unstated premise underlying the good character requirement—that law societies are capable of predicting future misconduct based on an applicant’s prior criminal records—is a valid one”: Ibid, p. 23-16.

[11] I should note that all variables were generally weak predictors; men had just a 3.5% chance of being disciplined (as compared to a 1% chance for women). The point here, to be clear, is not that we should be screening on the basis of gender (or traffic tickets), but that if the purpose of the requirement is to prevent the risk of future professional misconduct, the evidence to support screening based on criminal convictions and academic misconduct is even weaker than that which would support screening for this purpose based on gender or traffic violations.

[12] Law Society of Upper Canada submission on the Federation of Law Societies of Canada’s National Suitability to Practise Standard Consultation Report, November 2013, Professional Regulation Committee Report to Convocation, November 21, 2013, Tab 4.1, p. 70.

[13] Ibid, pp. 70-71.

[14] The 17^th and final question is broadest of all, asking, “Are there any matters not mentioned above that, when reasonably and objectively considered, might adversely reflect on the reputation of the legal and paralegal professions in Ontario or your ability to practise law or provide legal services should you be licensed?” In my view this question is a potential minefield for applicants, who need to decide whether to disclose something out of an abundance of caution (and open themselves up to a costly good character investigation) or risk the LSO taking the position that, by failing to disclose something that the LSO believes ought to have been disclosed under this catch-all heading, the candidate misled the LSO and should be disqualified from licensing pursuant to s. 8(2) of By-Law 4 (“An applicant who makes any false or misleading representation or declaration on or in connection with an application for a licence, by commission or omission, is deemed thereafter not to meet, and not to have met, the requirements for the issuance of any licence under the Act.”).

[15] Law Society Act, s. 27(4).

[16] LSUC v Armstrong, 2011 ONLSAP 1.

[17] Alice Woolley, “Can Good Character Be Made Better? Assessing the Federation of Law Societies’ Proposed Reform of the Good Character Requirement for Law Society Admission”, Canadian Journal of Administrative Law and Practice, 2013, online: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2262863 [Woolley]

[18] Woolley, p. 25.

[19] Woolley, p. 7.

[20] This number does not include paralegal licensing applicants and applications from formerly disbarred lawyers for re-admission into the profession. There has been just one good character decision in Ontario in 2025 at the time of writing, and that applicant was found not to be of good character; however, there were dissenting reasons and the matter is currently under appeal.

[21] There may well be applicants who withdrew from the licensing process before a hearing was determined, potentially because they determined they would not be found to be of good character. I do not believe there is any way for me to track this, and note in any event that those who withdrew their licensing application could also have done so simply because the process exhausted their resources or patience, regardless of whether they could have proven their good character in the end.

[22] Lawyers & Ethics, p. 23-9.

[23] See LSO Online Annual Reports: https://lso.ca/about-lso/governance/annual-report.

[24] LSO By-Law 4, s. 8(2): https://lso.ca/about-lso/legislation-rules/by-laws/by-law-4.

[25] See the discussion in my previous post.

[26] Woolley, p. 39.

[27] Rhode, p. 589.

[28] Woolley, p. 39

[29] See also Lawyers & Ethics, p. 23-20.

[30] Lawyers & Ethics, p. 23-16.