On 2 November 2006 the Bar Council noted that it was unable to make a determination under s68(3) of the Legal Profession Act 2004 with respect to the show cause event notified by Wayne Edward Russell.

The Bar Council further noted that an indefinite statutory suspension of the practising certificate of Wayne Edward Russell would follow in accordance with the provisions of s70 of the Legal Profession Act 2004 from 6 November 2006.

On 4 June 2007 the Legal Services Commissioner determined that Wayne Edward Russell is a fit and proper person to hold a practising certificate but that it is appropriate to impose financial management conditions on Wayne Edward Russell’s local practising certificate and on any local practising certificate held by Wayne Edward Russell with respect to any period up to 31 December 2010.

On 15 June 2006 the Bar Council issued a practising certificate to Wayne Edward Russell with conditions attached, being those determined by the Legal Services Commissioner.