LSO tribunal’s 2025 annual report highlights decisions made on licensing exam cheating allegations

The tribunal noted a considerable increase in conduct matters over the year

LSO tribunal’s 2025 annual report highlights decisions made on licensing exam cheating allegations

In its recently published 2025 annual report, the Law Society of Ontario Tribunal has highlighted its decisions on cases involving claims of cheating on the lawyer licensing examination.

The incident involved tutoring service NCA Exam Guru’s supposed sharing of banned exam materials to some lawyer and paralegal applicants seeking licensure in 2021 and 2022. The tribunal evaluated the applicants’ character in the exam-related misconduct context and the honesty of their statements across the licensing process.

In Butler v Law Society of Ontario, 2025 ONLSTH 91, Butler reportedly cheated in the June 2021 barrister exam and the November 2021 solicitor exam. She confirmed that she had used NCA Exam Guru to review for the exams but steadfastly asserted that she did not receive or use banned materials. The tribunal’s hearing division concluded that no direct evidence linked Butler to the materials, nor was she listed among the candidates who were given access to them.

By contrast, Kishan Jariwala’s application for a lawyer licence in Ontario was dismissed after the tribunal determined that his answers to the November 2021 solicitor exam were strongly similar to that on a cheating key. It also found that during the LSO’s investigation of the cheating incident, he did not disclose the banned exam materials and denied his awareness of the cheating key.

In Kaur v Law Society of Ontario, 2025 ONLSTH 108, a tribunal panel also shot down Kaur’s license application because she was found to have been part of a cheating scheme and deliberately used prohibited study materials. It determined that she had tried to mislead the LSO’s investigation, only confessing her participation in the scheme once faced with evidence. Applicant Phulka’s licensing bid was similarly shot down.

The tribunal revoked Harvinder Singh Saran’s lawyer licence, which he obtained through inter‑jurisdictional transfer from Nova Scotia in February 2022, after determining that he cheated on the November 2021 solicitor exam and was not of good character. David Peter Ginzberg’s Ontario licensing application was also dismissed after the tribunal found that he did not disclose the 2018 revocation of his licence to practise law in Florida after nine complaints were filed against him.

The tribunal said its judgments in these cases displayed a consistent focus on integrity, honesty, and accountability as facets of the good-character criterion.

Overall, the tribunal ordered 94 suspensions, 33 revocations, and 8 reprimands in 2025. Tribunal chair Malcolm M. Mercer wrote in the report that the tribunal saw “an exceptionally high volume of activity” driven by a notable increase in conduct matters. The number of notices filed by the Law Society to the tribunal ticked up as well in 2025 – a trend that will likely be sustained through 2026-2027.