It is not surprising that the law regulates the conduct of lawyers, especially when it comes to the lawyer’s duty to the client. In such relationships, lawyers are placed in positions of trust, with clients relying on them for their expertise, integrity, and judgement. The law thus obliges lawyers to act with utmost loyalty and care in dealing with their clients. Such duties are not restricted to situations where a lawyer expressly enters into a retainer agreement with a client (i.e. an express retainer). For example, where an express retainer is not established, but the parties nevertheless act in a manner which conveys a lawyer-client relationship, a retainer may still be implied, with similar duties imposed on the lawyer. Further, even if no retainer is established, a lawyer can still be sanctioned if his/her conduct is found to be unbefitting of a lawyer.