Permission to surrender is generally treated as the second-most serious penalty, imposed when a panel finds that a licensee should not continue to practise law and must leave the profession, but where the circumstances are less serious than those that warrant revocation. In either case, the public is protected as the licensee will no longer have a licence to practise: Law Society of Upper Canada v. Munir, 2017 ONLSTH 52 (CanLII).
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