Permission to surrender one’s licence has been ordered in cases that do not warrant loss of licence but where the licensee did not wish to continue practising law. The rationale for such an order was described in Law Society of Upper Canada v. Willoughby, 2015 ONLSTH 129 (at para. 20): 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 but the circumstances are less serious than those that warrant revocation. In our view, it can also be imposed in different circumstances. Sometimes, as here, a licensee facing discipline may not wish to continue practising law or providing legal services. There would be little point in requiring the licensee to serve a suspension, then surrender his or her licence. This approach allows licensees to make decisions that are best for them and also protects the public interest….
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