A Calgary-based lawyer has been suspended for six months after an independent hearing committee found he harassed and intimidated articling students and staff over an extended period, falsified legal documents, misled clients about their cases, and withdrew trust funds before issuing a billing.
The Law Society of Alberta’s hearing committee concluded that H.S. engaged in “conduct deserving of sanction” serious enough to warrant both a lengthy suspension and a referral to the Attorney General.
Suspension and costs
The sanction phase of the hearing took place virtually on Sept. 3, 2024. In its final report, released Dec. 5, 2024, the committee stated that the appropriate penalty was a six-month suspension starting Sept. 17, 2024, along with costs of $38,039.77 payable by Sept. 17, 2025. According to the report, “the fundamental purposes of sanctioning are to protect the public from acts of professional misconduct and to protect the public’s confidence in the integrity of the profession.”
The decision followed an earlier ruling on June 6, 2024, in which the committee found H.S. had repeatedly crossed professional boundaries.
The committee determined he “acted in an inappropriate manner with his students and employees,” and that this behaviour was neither an isolated nor a minor matter. Witnesses described the work environment as toxic, with one witness characterizing it as a “reign of terror.”
According to the Law Society of Alberta’s counsel, S.H., H.S.’s communications and actions left staff uncertain, fearful, and feeling as though they were constantly under threat.
Creation of false information
Besides the abusive conduct in the workplace, the committee found that H.S. had “participated in the creation of false information” in a revocation of a power of attorney document and filed it at the Land Titles Office, “knowing that it was false.” He also “commissioned an Affidavit of Execution knowing that it was false,” which, according to the committee, struck “at the very heart of the integrity of the profession.” This document fabrication aimed to cover up previous failures in dealing with a mortgage registration that had gone unaddressed for over a year.
The hearing committee noted that H.S.’s misconduct extended beyond staff interactions and document falsifications. It found that he “failed to provide three separate sets of clients with thorough, conscientious and diligent service” and “provided false information to a client” over an extended period. H.S. consistently misled one client about the status of a matter, claiming documents had been filed when they had not, and even inventing a hearing date that never took place. The ruling stated that his misleading conduct was “of a ‘cradle to grave’ nature,” beginning early in the file and continuing until he took funds from trust before issuing a proper statement of account. The report noted that he charged for work not actually performed.
The Law Society’s counsel had recommended a suspension of four to six months, full payment of hearing costs, and a referral to the Attorney General. S.H. highlighted that each category of misconduct—harassing staff, filing false documents, misleading clients, and breaching trust accounting rules—could individually justify a suspension of several months. Taken together, the Law Society argued that an overall suspension of four to six months was “more than reasonable.”
Lawyer sought shorter suspension
H.S. represented himself at the sanction hearing. He introduced documents from the Practice Review Committee (PRC) meant to show some degree of cooperation and improvement in his practice management. He argued for a shorter suspension in some areas, citing cases in which lawyers who engaged in abusive communications or falsification of documents received less severe penalties. Yet, the committee did not find these comparisons persuasive given the weight of the aggravating factors, the length of the misconduct, and the vulnerability of those affected.
On the issue of harassment and intimidation, H.S. conceded that a suspension was justified but suggested a shorter duration. In its analysis, the committee focused on aggravating elements, including the deliberate and repeated nature of the mistreatment, the severe personal impact on staff and students, the power imbalance, and the lack of any genuine apology. While H.S. had no prior discipline record, the committee found that factor insufficient to reduce the overall penalty significantly. For this aspect of the misconduct alone, the committee concluded a two-month suspension would have been warranted, underscoring the seriousness of the conduct toward staff.
On the falsification of documents, including the false Revocation and affidavit, the committee found the misconduct particularly grave. H.S. not only knew the documents were false but also intended them to obscure his own failures and benefit himself. The committee considered precedents ranging from short suspensions to much longer ones but found that the deliberate, dishonest nature of the conduct supported a two-month suspension on its own.
The extended and repetitive misleading of a client also warranted serious attention. H.S. repeatedly lied about the status of the client’s legal matter, fabricated hearing dates, and misrepresented the filing of documents. While some cases in the past have led to lesser penalties for isolated or less serious client misrepresentations, the comprehensive pattern in H.S.’s dealings and the trust account irregularities weighed heavily in determining the final sanction. The committee noted that even if considered on its own, this pattern of dishonesty would have merited a significant suspension.
Three categories of misconduct
Combining all three categories of misconduct — workplace harassment, falsifying documents, and misleading clients — the committee decided an aggregate suspension of six months was appropriate. It wrote that suspensions are meant to protect the public and uphold the profession’s integrity. The overall decision “reflects both the evolving higher standards of conduct expected” and the need for denunciation.
Regarding costs, the committee considered the “default rule” in awarding them to the Law Society. While H.S. argued for a reduction, pointing to partial success on one citation and the Law Society’s decision to call witnesses on matters already admitted, the committee ultimately ordered him to pay the full costs of $38,039.77. Although H.S. had some measure of cooperation, the seriousness of the misconduct and the demands placed on the regulatory process left the committee unpersuaded to reduce the amount.
The committee also ordered a referral of the matter to the Attorney General. Though it did not find H.S. personally forged a signature, it concluded that by directing his assistant to commit forgery and commissioning a false affidavit, he was a participant in potentially criminal activity. The report noted that the actions “fall within the provisions of section 366(2)(b)” of the Criminal Code, which deals with forgery offences. By sending a copy of the hearing record to the Attorney General, the committee indicated reasonable grounds to believe H.S. had committed a criminal offence.
In addition to the suspension and costs, the committee ordered that notice to the profession be issued and that the hearing materials be made available for public inspection, with appropriate redactions to protect the identities of clients and staff.
For more information see Law Society of Alberta v Sangha, 2024 ABLS 24 (CanLII).
