Fuhad Ahmed
Employee
7615011

Decision - Employee-related decision

Outcome: Control of non-qualified staff (Section 43 / Section 99 order)

Outcome date: 11 August 2025

Published date: 6 October 2025

Firm details

Firm or organisation at time of matters giving rise to outcome

Name: Wilden Legal Solictors

Address(es): 2-12 Cambridge Heath Road, LONDON, E1 5QH

Firm ID: 665988

Outcome details

This outcome was reached by SRA decision.

Decision details

Who does this decision relate to?

Mr Fuhad Ahmed whose last known address was in Tower Hamlets, London.

A person who is or was involved in a legal practice but is not a solicitor.

Summary of decision

The SRA has put restrictions on where and how Mr Ahmed can work in an SRA regulated firm.

It was found that: Mr Fuhad Ahmed, who is not a solicitor, was involved in a legal practice and has occasioned or been a party to an act or default which involved such conduct on his part that it is undesirable for him to be involved in a legal practice in any of the ways described in the order below.

The facts of the case:

Mr Ahmed prepared a fabricated expert psychological report purporting to be authored by the said psychological expert. He then proceeded to serve the report on the court on behalf of a client.

Mr Ahmed is not a qualified psychologist. Decision on outcome An order pursuant to section 43(2) of the Solicitors Act 1974 was imposed as Mr Ahmed's conduct meant that it was undesirable for him to be involved in a legal practice without the SRA's prior approval.

The order pursuant to section 43 was made with effect from the date of the letter or email notifying Mr Ahmed of this decision: Mr Ahmed was found to have prepared and submitted a fabricated psychological report to the court.

Mr Ahmed's conduct was serious and dishonest because he fabricated an expert report, falsified the contents and submitted it to the court as a valid document, which it was not.

Mr Ahmed was also ordered to pay a proportion of the SRA's costs of £600.

What our Section 43 order means

1. no solicitor shall employ or remunerate him in connection with his/her practice as a solicitor;
2. no employee of a solicitor shall employ or remunerate him in connection with the solicitor's practice;
3. no recognised body shall employ or remunerate him;
4. no manager or employee of a recognised body shall employ or remunerate him in connection with the business of that body;
5. no recognised body or manager or employee of such a body shall permit him to be a manager of the body; and
6. no recognised body or manager or employee of such a body shall permit him to have an interest in the body except in accordance with the SRA's prior written permission

Reasons/basis

Decision

I have decided as follows:

1.1 To make a section 43 order that with effect from the date of the letter or email notifying Fuhad Ahmed of this decision:

1.1.1 no solicitor shall employ or remunerate him in connection with his practice as a solicitor;

1.1.2 no employee of a solicitor shall employ or remunerate him in connection with the solicitor’s practice;

1.1.3 no recognised body shall employ or remunerate him;

1.1.4 no manager or employee of a recognised body shall employ or remunerate him in connection with the business of that body;

1.1.5 no recognised body or manager or employee of such a body shall permit him to be a manager of the body; and

1.1.6 no recognised body or manager or employee of such a body shall permit him to have an interest in the body

1.1.7 except in accordance with the SRA’s prior written permission.

1.2 The section 43 order in respect of Mr Fuhad Ahmed shall be published.

1.3 Fuhad Ahmed is ordered to pay the sum of £600 in relation to the SRA’s costs of investigating this matter.

1.4 My reasons are set out in sections 6, 7 and 8. l

2. Matters considered

2.1 I was asked to:

2.1.1 Make a finding in respect of the allegation.

2.1.2 Make a finding of dishonesty against Mr Fuhad Ahmed.

2.1.3 Make an order pursuant to section 43(2) of the Solicitors Act 1974 in relation to Mr Ahmed and to publish this.

2.1.4 Direct that Mr Fuhad Ahmed pays the SRA’s costs of £600 in investigating this matter.

2.2 It was alleged that Mr Ahmed prepared and submitted a fabricated psychological report to the Immigration Court.

3. Findings

3.1 I find the allegation proven.

3.2 Mr Ahmed’s conduct was dishonest.

3.3 By virtue of the above, it is undesirable for Mr Fuhad Ahmed to be involved in a legal practice without the SRA’s prior written consent.

4. Summary of facts and issues

4.1 I have received and considered a notice dated 17 February 2025 (A1-A9) prepared by Satbachan Kaur Bahia, investigation officer, together with the documents attached at B1-B69, C1- C28 and D1-D28.

4.2 The facts of this matter are set out in the investigation officer’s notice and the appendices. In summary, Mr Fuhad Ahmed was employed at Wildan Legal Solicitors (the Firm) as a case worker from 20 September 2023 until he was dismissed for gross misconduct on 18 December 2023.

4.3 The Firm were instructed in respect of an immigration hearing and the client was advised to obtain a psychological report in respect of the claim. The client paid the firm £500 for this to be prepared.

4.4 Subsequently the client had a telephone assessment with an expert psychologist. Following this Mr Ahmed contacted the expert psychologist and requested the psychologist report to be completed by 10pm on the same date as it needed to be served at court.

4.5 The expert psychologist was not able to accommodate the request within the timescale due to a prior commitment, however Mr Ahmed proceeded to draft and submit an expert psychological report purporting to be authored by the said psychological expert and served it on the court on behalf of the client. Mr Ahmed is not a qualified psychologist.

4.6 It subsequently transpired that there were a number of inaccuracies and inconsistencies in the report which led the client to contact the expert psychologist who confirmed that she had never drafted the report. The client subsequently made a complaint to the SRA who then investigated the matter with the Firm.

4.7 During the Firm’s investigation into the matter Mr Ahmed admitted that he had prepared the psychological report and submitted it to the court.

5. Legal and Regulatory Framework

5.1 Extracts from the relevant rules and regulations are contained in section D of the documents appended to the notice.

5.2 In making my decision I have taken into account the regulatory objectives, in particular promoting and protecting the public interest and the interests of consumers.

5.3 The standard of proof is the balance of probabilities. The burden of proof is on the SRA. Dishonesty

5.4 The test we apply when considering dishonesty is set out by Lord Nicholls in Royal Brunei Airlines Sdn Bhd v Tan [1995] 2 AC 378 and by Lord Hoffmann in Barlow Clowes International Ltd v Eurotrust International Ltd [2005] UKPC 37. That test was confirmed by the Supreme Court in Ivey (Appellant) v Genting Casinos (UK) Ltd t/a Crockfords (Respondent) [2017] UKSC 67.

5.5 In short, I must first ascertain the actual state of Mr Ahmed’s knowledge or belief as to the facts. Once ascertained, the question of whether his conduct was dishonest must be determined by applying the objective standards of ordinary decent people. Section 43

5.6 In brief, I must be satisfied of the following:

5.6.1 Mr Ahmed is not a solicitor. 5.6.2 He is or was involved in a legal practice.

5.6.3 He has occasioned or been a party to, with or without the connivance of a solicitor, an act or default in relation to a legal practice.

5.6.4 That act or default involved conduct on his part of such a nature that it would be undesirable for him to be involved in a legal practice in one or more of the ways set out in subsection 43 (1A) of the Solicitors Act 1974. Publication

5.7 My decision must be published unless I decide the particular circumstances outweigh the public interest in publication (Rule 9.2 of the SRA Regulatory and Disciplinary Procedure Rules). I must also consider the SRA guidance on publishing regulatory and disciplinary decisions. Costs

5.8 If I make a section 43 order, I also need to consider the issue of costs in accordance with rule 10 of the RDPR.

6. Findings

6.1 In connection with the allegation that Mr Ahmed prepared and submitted a fabricated psychological report to the Immigration Court, I find that this allegation is proven.

6.2 Mr Ahmed admitted to preparing the psychological report without, it seems, involvement of any other party. He is reported to have explained that he acted independently fearing client frustration and potential disappointment and a fear of losing his job.

6.3 Mr Ahmed had made no independent representations in connection with this matter, nor has he provided any explanation which justifies his actions in the circumstances.

Dishonesty

6.4 I find that Mr Ahmed acted dishonestly when producing a psychological expert report and filing it at court as a legitimate document to be used in legal proceedings.

Section 43 order

6.5 The purpose of a section 43 order is to prevent non-solicitors from being employed or remunerated by solicitors and their firms without permission. A section 43 order relates only to individuals who are not solicitors.

I am satisfied that Mr Ahmed is not a solicitor.

6.6 In order to impose a section 43 order Mr Ahmed must be, or have been, involved in a legal practice in one or more of the ways set out in section 43(1A) (a) to (d) of the Solicitors Act 1974. In this case, I am satisfied that Mr Ahmed was undertaking work in the name or, or under the direction or supervision of, a solicitor.

6.7 I must also be satisfied that Mr Ahmed’s conduct was in relation to a legal practice. I find that his actions were in relation to a legal practice as they are typical of actions that would have been carried out during the course of his employment in a legal practice in that he was responsible for filing documents at court.

6.8 Before taking any regulatory action, I must be satisfied that the nature of the misconduct, which I have found to have occurred evidences that it isundesirable for Mr Ahmed to be involved in a legal practice in one or more of the ways mentioned in subsection 43 (1A) of the Solicitors Act 1974. This is the allegation raised in the notice.

6.9 The High Court explained the purpose of a Section 43(2) Order in R (on the application of the Solicitors Regulation Authority) v Solicitors Disciplinary Tribunal and Solicitors Regulation Authority v Liaqat Ali [2013] EWHC 2584 Admin, at paragraph 41:

'As they themselves [the Solicitors Disciplinary Tribunal] acknowledge, the section 43 order has a regulatory function, not a penal function. That is why the order is of indefinite duration, subject to revocation upon review. The purpose of the order is to safeguard the public and the [Law] Society’s reputation by ensuring that a person is currently only employed where a satisfactory level of supervision has been organised and for as long as that person requires such level of supervision before being permitted to work effectively under his own steam.'

6.10 Mr Ahmed’s conduct was serious. He fabricated an expert report, falsified the contents and submitted it to the court as a valid document. There were a number of steps required during the course of this conduct where the seriousness of this must have been clearly apparent to Mr Ahmed. In addition, Mr Ahmed has not provided any reasonable explanation or justification for his actions.

6.11 I have found that Mr Ahmed’s actions were dishonest. This is a serious matter for a member of a profession whose reputation depends on trust. Honesty isrequired from all those involved in the provision of legal services and Mr Ahmed has proved that he can act without this.

6.12 Sir Thomas Bingham confirmed in Bolton v The Law Society that, for solicitors, a finding of dishonesty would often result in strike off. He said: "In such cases the Tribunal has invariably, no matter how strong the mitigation advanced for the solicitor, ordered that he be struck off the Roll."

6.13 The reason for such an approach is primarily two-fold. The first is to protect the public by ensuring that such individuals do not have the opportunity to engage in similar misconduct in the future. This is achieved in the long-term by striking him or her off the roll, and in the shorter term by a period of suspension. The second is to maintain public confidence in the legal profession as one in which every member of whatever standing can be trusted to the ends of the earth.

Mr Ahmed may not be a solicitor, but this does not mean he should not be made subject to similar control.

6.14 Mr Ahmed’s conduct, which was dishonest, warrants imposing a section 43 order. For the reasons set out above, the nature and severity of his conduct justifies prohibiting him from being involved in a legal practice in the ways set out in section 43(2) of the Solicitors Act 1974 without the SRA’s consent.

6.15 The order imposed will ensure the public are protected by preventing solicitors and firms regulated by the SRA from employing or remunerating Mr Ahmed without prior approval. It will also prevent such firms from allowing himto be a manager or from having an interest in them without prior approval.

This will enable the SRA to consider Mr Ahmed’s proposed working environment and whether this provides sufficient support and supervision to ensure that clients and the public are adequately protected. The restriction imposed on his ability to work and to be involved in a legal practice will also maintain public confidence in the legal profession.

6.16 For the above reasons, I am satisfied that the decision to make a section 43 order is an effective regulatory outcome which will protect and promote the public interest.

6.17 I have decided that the section 43 order shall have effect from the date of the letter or email notifying Mr Ahmed of this decision. I am satisfied that it is in the public interest for this order to have immediate effect because of the seriousness of Mr Ahmed’s misconduct.

7. Costs

7.1 I have been asked to award costs of £600 on the basis that up to 8 hours has been incurred investigating this matter. I note Mr Ahmed has not provided any representations against the recommended cost order.

7.2 I have considered Rule 10 and schedule 1 to the RDPR and the work conducted on this matter.

7.3 Having considered these, I have decided to order that Mr Ahmed should pay costs of £600.

8. Publication

8.1 Rule 9.2 of the RDPR states that section 43 orders shall be published unless there are circumstances which outweigh the public interest in publishing.

8.2 Our decision-making guidance on publishing regulatory and disciplinary decisions provides a list of factors which may support a decision not to publish. I find that none of these factors apply.

8.3 As I have directed that the order should have immediate effect, the decision should be published from the date of the letter or email notifying Mr Ahmed of this decision. Duncan Reed Adjudicator