Manifest incompetence needs systemic or fundamental failure, not one badly handled file. Two Solicitors Disciplinary Tribunal outcomes reported within days of each other, one a strike-off and one a reprimand on a split decision, mark out where the line between poor service and misconduct now sits in conveyancing. Both began with post-completion registration.
What did the tribunal decide in each case?
Simon Langford, owner, manager and sole solicitor at Sayers Solicitors in Harrow Weald, was struck off after admitting dishonesty. He was ordered to pay costs of £45,630, and the Solicitors Regulation Authority intervened into the firm and into his practice on 17 July 2026 following the tribunal’s order.
The conduct spanned three matters. A client’s purchase completed in June 2019; the firm’s registration application was rejected two months later and no further application was made. When the client noticed in mid-2020 that the property was not appearing on sold-price websites and raised it, she received assurances on as many as seven occasions over the following three years that the application was lodged. She learned the truth from HM Land Registry in 2023. On a separate matter the firm gave an undertaking to another conveyancing practice to register a lease extension within three days of completion, then ignored 26 emails, 22 phone calls and two letters. On a third, five emails from another firm chasing information for a requisition went unanswered.
The second outcome went the other way, and it is more useful. A solicitor admitted in 2002, a partner at a Stevenage firm, faced two allegations arising from a single property transfer handled during the pandemic. The first was proven: he failed to provide his client with adequate information about the terms of his instruction and client care arrangements. The second was dismissed. That allegation was that he had communicated with, and taken instructions from, the transferee, who was the client’s son.
Where does manifest incompetence begin?
The regulator advanced manifest incompetence as an aggravating feature in the second case, and the tribunal rejected it, being satisfied that the proven misconduct arose in the context of a single transaction and did not demonstrate the systemic or fundamental lack of competence that the finding requires. The solicitor’s evidence had emphasised exactly that: one conveyancing transaction, no pattern, no repetition, across a career of 23 years without previous findings.
That is a threshold with real content, and it is being applied consistently. Manifest incompetence has elsewhere been found where a solicitor’s conduct across his roles as manager, compliance officer for legal practice and compliance officer for finance and administration, and in his handling of conveyancing transactions generally, fell below the standard, and even then it produced a suspension rather than a strike-off because no ethical breach was involved. The distinguishing feature in each instance is scope. One file is not a system.
The sanction reasoning followed from that finding, and it is worth reading in full, because the tribunal treated the misconduct as too serious for no action on the basis that the failures concerned fundamental obligations owed to a client and leaving them unmarked could undermine public confidence in the profession. It then placed the conduct at the lower end of the spectrum of seriousness, found no aggravating features, and imposed a reprimand.
Why does registration keep appearing?
Post-completion is where both of these files started, and that is not coincidence. It is the stage of a conveyancing matter most likely to drift, because the client has moved in, the money has gone, and nothing visible depends on the application until the day something does. It is also the stage where a reassuring email is easiest to send and hardest to justify afterwards.
The distinction the tribunal drew maps onto that neatly. A single transaction handled badly is a service failure and, at worst, a reprimand, whereas a sustained pattern of telling a client that something has happened when it has not is dishonesty, and dishonesty in the absence of exceptional circumstances remains a strike-off. What moved the first case across the line was not the delay. It was the seven assurances.
Firms should read the second outcome as a warning about client care documentation rather than as a reprieve, because the allegation that succeeded was the unglamorous one about terms of instruction and client care arrangements, while the more colourful allegation about taking instructions from the client’s son is the one that failed. Regulatory risk in conveyancing sits in file discipline more often than in judgment calls.
What should firms check now?
Three things follow for supervision. Registration applications rejected by the registry need a route back into the workflow that does not depend on the fee earner remembering, because a rejection that produces no follow-up application is invisible until a client checks a price website. Undertakings given to other firms need to be tracked against a diary rather than an intention. And any file where a client has asked the same question more than twice should be a supervision trigger, since repeated enquiries are what preceded both the assurances and the eventual referral.
The disciplinary end of this pipeline connects directly to the service end. The Legal Ombudsman’s conveyancing complaint volumes have been rising sharply, and post-completion delay is a substantial part of that. Most of those files never reach a tribunal. The ones that do tend to have crossed from delay into explanation.
The tribunal is drawing a workable distinction. A single transaction handled badly is a service failure and, at worst, a reprimand, while a pattern of misleading a client about what has actually happened on their file is a strike-off. Post-completion registration is where both of these cases started, which is not a coincidence. It is the stage of a conveyancing file most likely to drift, and the stage where a reassuring email is easiest to send and hardest to justify later.
The two outcomes compared
| Strike-off | Reprimand | |
|---|---|---|
| Scope of conduct | Three matters over several years | One transfer |
| Nature of failure | False assurances, admitted dishonesty | Inadequate client care information |
| Manifest incompetence | Not the basis of the finding | Alleged and rejected |
| Mitigation weight | Long career, partner’s death, ill health of practice | Unblemished 23 years, admissions, cooperation |
| Costs | £45,630 | Not the determining feature |
Tribunal judgments are published by the Solicitors Disciplinary Tribunal, and intervention and sanction records appear on the SRA’s recent decisions page. Firms reviewing their own exposure should read both against the regulator’s current enforcement priorities.
For the service-complaint counterpart to this, see our coverage of the 41% rise in conveyancing complaints at the Legal Ombudsman, and for the supervision framework the tribunal is measuring against, our firm-wide risk assessment checklist.