Ignatius Sunday Etukudoh

Decision - Sanction

Outcome: Rebuke

Outcome date: 5 August 2025

Published date: 12 August 2025

Firm details

Firm or organisation at date of publication and at time of matters giving rise to outcome

Name: Alpha Springs Solicitors Ltd

Address(es): Suit 4 - Station Chambers, High Street North, East Ham, London E6 1JE

Firm ID: 8003511

Outcome details

This outcome was reached by SRA decision.

Reasons/basis

1. Agreed outcome

1.1 Mr Ignatius Etukudoh, a solicitor and former sole practitioner of Alpha Springs Solicitors (the firm), agrees to the following outcome to the investigation of his conduct by the Solicitors Regulation Authority (SRA):

1. he is rebuked
2. to the publication of this agreement
3. he will pay the costs of the investigation of £300.

2. Summary of Facts

2.1 From 10 October 2022 until 22 November 2023 Mr Etukudoh was the sole practitioner of Alpha Springs Solicitors. On 23 November 2023 the firm was succeeded by Alpha Springs Solicitors Limited, which Mr Etukudoh is sole director of.

2.2 In December 2022 a non-qualified caseworker at the firm made an application to the Immigration and Asylum Tribunal for permission to apply for a judicial review of a Home Office decision made in respect of Client A.

2.3 In March 2023 an Upper Tribunal Judge refused the application and certified it as totally without merit.

In May 2023 an Upper Tribunal Judge made a wasted costs order of £1,492 against the firm.

2.4 The SRA reviewed Client A’s file and found the following issues consistent with the Upper Tribunal’s certification that the claim was totally without merit. The application:

1. failed to adhere to the Pre-Action Protocol for Judicial Review
2. was inappropriately submitted under the urgent consideration procedure
3. failed to provide key documents, including the submissions to the Home Office in relation to the decision being challenged.
4. was poorly drafted.

2.5 Mr Etukudoh confirmed that lessons have been learned following this application. He has implemented process changes to ensure that every appeal application will receive appropriate advice on merits and prospects of success.

3. Admissions

3.1 Mr Etukudoh admits and the SRA accepts that by allowing, or failing to prevent, a non-qualified employee of his firm from submitting a meritless application for permission to apply for judicial review, he has breached:

1. Paragraphs 2.4, 2.6 and 3.5 of the SRA Code of Conduct for Solicitors, RELs and RFLs; and
2. Principles 1 and 2 of the SRA Principles.

4. Why a written rebuke is an appropriate outcome

4.1 The SRA’s Enforcement Strategy sets out its approach to the use of its enforcement powers where there has been a failure to meet its standards or requirements.

4.2 When considering the appropriate sanctions and controls in this matter, the SRA has taken into account the admissions made by Mr Etukudoh and the following mitigation which he has put forward:

1. he has cooperated with the SRAs investigation
2. he has shown insight and understanding of his regulatory obligations
3. he has expressed remorse, regret and apologised for the misconduct
4. there have been no adverse regulatory decisions made against him previously.

4.3 The SRA considers that a written rebuke is the appropriate outcome because:

1. Mr Etukudoh failed to support the effective administration of justice.
2. the risk of repetition is low
3. some sanction is required to uphold public confidence in the delivery of legal services.
4. The SRA does not consider that it is proportionate or in the public interest to pursue allegations to the Tribunal. A rebuke reflects the gravity of and seriousness of the conduct without requirement for further sanctions.

5. Publication

1.1 The SRA considers it appropriate that this agreement is published in the interests of transparency in the regulatory and disciplinary process. Mr Etukudoh agrees to the publication of this agreement.

6. Acting in a way which is inconsistent with this agreement

6.1 Mr Etukudoh agrees that he will not deny the admissions made in this agreement or act in any way which is inconsistent with it.

6.2 If Mr Etukudoh denies the admissions or acts in a way which is inconsistent with this agreement, the conduct which is subject to this agreement may be considered further by the SRA. That may result in a disciplinary outcome or a referral to the Solicitors Disciplinary Tribunal on the original facts and allegations.

6.3 Denying the admissions made or acting in a way which is inconsistent with this agreement may also constitute a separate breach of principles 2 and 5 of the Principles and paragraph 7.3 of the Code of Conduct for Solicitors, RELs and RFLs.

7. Costs

7.1 Mr Etukudoh agrees to pay the costs of the SRA's investigation in the sum of £300. Such costs are due within 28 days of a statement of costs due being issued by the SRA.