Jonathon Howard
Bostock
Non-lawyer manager
597295
Decision - Employee-related decision
Outcome: Control of non-qualified staff (Section 43 / Section 99 order)
Outcome date: 23 June 2026
Published date: 30 June 2026
Firm details
Firm or organisation at time of matters giving rise to outcome
Name: PM Law Limited
Address(es): PM House, 250 Shepcote Lane, Sheffield, S9 1TL
Firm ID: 421374
Outcome details
This outcome was reached by SRA decision.
Decision details
Who does this decision relate to
Jonathon Howard Bostock, who is not a solicitor, was, from 1 January 2013 until 2 February 2026, a non-lawyer manager and Head of Finance and Administration (HOFA) of the licensed bodies (and Compliance Officer for Finance and Administration of the recognised bodies) which made up the PM Law group.
Summary of decision
Mr Bostock was made subject to a disqualification order under section 99 of the Legal Services Act 2007.
The SRA has disqualified Mr Bostock from holding any of the following roles in law firms regulated by the SRA:
- Head of Legal Practice
- Head of Finance and Administration
- A manager
- An employee.
Reasons/basis
The facts of the case
The firms in the PM Law Group contained six recognised bodies and six licensed bodies. Mr Bostock is a chartered accountant. He held the role of compliance officer for finance and administration (COFA) in the recognised bodies and head of finance and administration (HOFA) in the licensed bodies.
Mr Bostock exercised senior managerial control and financial authority across the firm, including oversight of its financial controls. He led the firm's accounts team and reported to Donald Mackay, solicitor, owner and chairman of the firm.
On 2 February 2026 the firm notified the SRA of serious concerns around the misuse of client money which may have rendered it effectively insolvent. On 4 February 2026, the SRA intervened into all but one of the firms that made up PM Law Group. The interventions were on the grounds that it was necessary to intervene to protect the interests of clients or former clients, the interests of beneficiaries of any trust of which any of the bodies is or was a trustee in that person's capacity as a manager or employee.
It was found that Mr Bostock:
Allegation 1
Caused, or allowed to be caused, withdrawals from PM Law client accounts which led to a client account shortage and thereby breached any or all of the following:
Paragraphs 5.2 and 9.2(a) of the SRA Code of Conduct for Firms; Principles 4, 5, 7 and 2 of the SRA Principles; and various breaches of the SRA Accounts Rules
Allegation 2
Failed to report to the SRA that PM Law was experiencing serious financial difficulty in consequence of the significant and worsening client account shortages, and thereby breached any or all of the following:
Paragraphs 3.6, 3.8, 3.9, 9.2(b) and 9.2(c) of the SRA Code of Conduct for Firms;
Principles 4, 5, 7 and 2 of the SRA Principles.
Allegation 3
Provided the SRA with documents and information which he knew or ought to have known to be false and misleading and thereby breached any or all of the following:
Paragraphs 1.4, 3.2 and 3.3 of the SRA Code of Conduct for Firms; and/or
Principles 4, 5, and 2 of the SRA Principles
Allegation 4
Fabricated the bank balances on a number of client and office accounts operated by the firm and used these to mislead another as to the firm's financial position.
In so doing, he breached any or all of the following:
Paragraph 1.4 of the SRA Code of Conduct for Firms; and/or
Principles 4, 5, and 2 of the SRA Principles.
And in doing so he committed serious breaches of regulatory duties owed by him in relation to the Licensed Bodies that were members of the relevant group and in which he held senior roles such as to make it undesirable for him to carry out activities as HOLP, HOFA, manager or employee (as defined by the SRA Glossary) of a Licensed Body.
Our decision on sanction
Mr Bostock's conduct breached relevant duties that applied to him as manager and HOFA at the firm, namely the SRA Principles, the SRA Accounts Rules and the SRA Code of Conduct for Firms.
It was found that it would be undesirable for Mr Bostock to act as a Head of Legal Practice, Head of Finance and Administration, a manager or employee of a body licensed in accordance with section 99 of the Legal Services Act 2007.
Mr Bostock was disqualified from holding any of these roles.
He was also directed to pay costs of £1,350.