In The Matter Of An Application By Skeeta Indira Sancheria John To Be Admitted To Practise As An Attorney -at- Law In Saint Lucia

THE EASTERN CARIBBEAN SUPREME COURT IN THE HIGH COURT OF JUSTICE CIVIL DIVISION SAINT LUCIA Case Number: SLUHCV2025/0135 -and- IN THE MATTER of Section 15 of the Legal Profession Act. Cap. 2.04 of Revised Laws of Saint Lucia IN THE MATTER of an application by SKEETA INDIRA SANCHERIA JOHN to be admitted to practise as an Attorney -at- Law in Saint Lucia. BETWEEN: SKEETA INDIRA SANCHERIA JOHN Applicant Before the Honourable Mr. Justice Alvin S. Pariagsingh Appearance: Mr. Anthony Bristol and Mr. Leslie K. Prospere for the Applicant1. -------------------------- 2025: April 14 – hearing April 17 – written submissions April 23 – decision -------------------------- JUDGMENT Application for Admission to Practise as an Attorney at Law in Saint Lucia pursuant to Section 15(1)(d) of the Legal Profession Act, Cap. 2.04 of the Revised Laws of Saint Lucia.

[1]PARIAGSINGH, J:- Before the Court is an application by Skeeta Indira Sancheria John to be admitted to practise as an Attorney-at-Law in Saint Lucia pursuant to section 15(1)(d) of the Legal Profession Act (‘the LPA’)2.

[2]Admission to practise is a privilege, even a person who is qualified to practise can be refused admission if the Court is of the opinion that the Applicant is not of good character. In assessing eligibility, the Court must look at all the statutory requirements and not just qualifications; See Layne v Attorney General of Grenada3.

[3]It is also well settled that the discretion to assess and examine applicants as to their learning and qualifications and to admit them to practise has always been exercised by the judiciary and it rest exclusively with the Court to determine who is qualified to become one of its officers; See Re: Admission of Andrew Ian James King, Rhea Harrikissoon and Bilal Mahmad4.

FACTS:

[4]The Applicant is a Saint Lucian by birth but currently resides in Trinidad and Tobago. She completed her Bachelor of Laws degree with the University of London and was awarded her LLB on 1 August 2014. She obtained a Certificate of Higher Education and a Postgraduate Diploma from the University of Westminster in October 2015 (the LPC’). She was admitted to practise as an Attorney-at-Law in Trinidad and Tobago on 16 April 2016 and holds a practising certificate for the current law year 2024/2025 in that jurisdiction. She now seeks admission in this jurisdiction pursuant to section 15(1)(d) of the LPA.

[5]In support of her application, in addition to her academic qualifications, she relies on a Certificate of Good Standing dated 12 March 2025 issued by the Law Association of Trinidad and Tobago. In her affidavit in support of her application, she deposes, “… that I possess the professional qualifications and experience to practise law in Saint Lucia.”

[6]There is no issue as to the Applicant’s character as in Layne (supra). In further support of her application, she has also produced a Certificate of Character from the Trinidad and Tobago Police Service dated 6 March 2025. The Applicant has also paid the requisite fee for admission in Saint Lucia.

[7]This application was assigned to this Court on 7 April 2025. Upon perusing same, the Court had concerns about whether the Applicant met the legal requirements for admission to the Bar of Saint Lucia. Counsel for the Applicant was invited to address the Court on 14 April 2025. Also, by the date of hearing, the Applicant had filed a supplemental affidavit on 11 April 2025.

[8]At the hearing on 14 April 2025, it was clarified that the Applicant was not seeking admission pursuant to section 15(1)(c), the ‘Solicitor’s route’, but rather pursuant to section 15(1)(d), commonly referred to as ‘the historical route’. The Court then gave the Applicant permission to file submissions in support of her application, including specifically on the following two issues: 1) Whether the route for qualification as a solicitor, as set out in section 15(1)(d) of the LPA, continued to exist after 1993 when the Legal Practice Course (LPC) was introduced? and if so, 2) In considering the matters set out in subsection (2) of section 15, how is the Court to treat the Applicant’s evidence of attachment to chambers/ good standing in light of paragraph 74 of the Court of Appeal judgment in The Attorney General of Trinidad and Tobago v Dianne Jhamilly Hadeed5? ISSUES:

[9]The issues which arises in this application is whether the admission route under section 15(1)(d) of the LPA still applies, and if so, whether the Applicant meets the requirements for admission as set out in that provision.

ANALYSIS:

[10]Saint Lucia has three broad categories of persons eligible to be entered on the Roll as ‘Attorneys-at-Law’: Barristers, Solicitors, and Attorneys-at-Law. All Attorneys at Law are also Notary Royals.

[11]Admission is further divided into two categories of applicants: citizens, whose eligibility criteria are set out in section 15 of the LPA, and non-citizens, whose criteria are governed by section 16 of the LPA. The Applicant falls within the ambit of section 15, as evidenced by her affidavit and her Saint Lucian passport exhibited in support.

[12]There are five routes to admission set out in section 15(1) of the LPA for citizens of Saint Lucia. Once an applicant satisfies any one of these routes, they are eligible for admission, subject to the additional requirements in subsection (3) and section 16. The five routes are: “(a) any English or Irish barrister-at-law, or any Scottish advocate; (b) any barrister or advocate of any of the Superior Courts of any British Possession where similar privileges are accorded to barristers of the Supreme Court; (c) any solicitor of the United Kingdom or Law Agent admitted to practise in Scotland; (d) subject to subsection (2), any person who, being not less than 18 years and otherwise qualified, shall have passed the intermediate and final examinations of the Law Society of England; or (e) any person of not less than 18 years who has obtained the Legal Education Certificate awarded by the Council of Legal Education.”

[13]Subsections (a) and (e) clearly do not apply to the Applicant, as she is neither an English or Irish barrister nor the holder of a Legal Education Certificate.

[14]Subsection (b) also does not apply. Although Counsel Mr. Bristol submitted orally that Trinidad and Tobago, where the Applicant practises, qualifies as a ‘British Possession’ with a ‘Superior Court’, this point was not developed in the written submissions filed by Mr. Prospere.

[15]In any event, I take a different view. While the Supreme Court of Trinidad and Tobago may historically have been regarded as a Superior Court of a British possession, that characterisation no longer holds. Trinidad and Tobago's judiciary now functions with full constitutional autonomy, and the Supreme Court of Judicature derives its authority from its own domestic legislation, namely the Constitution and the Supreme Court of Judicature Act. Though the country retains the Judicial Committee of the Privy Council as its final appellate court, that is a matter of sovereign choice, not colonial subordination. Accordingly, the Supreme Court of Trinidad and Tobago cannot be regarded as a ‘Superior Court of a British Possession’ for the purposes of section 15(1)(b) of the LPA.

[16]Subsection (c) does not apply either, as the Applicant is not a solicitor of the United Kingdom, nor a Law Agent admitted in Scotland. She has completed only two of the five steps typically required for admission as a solicitor in the UK: a qualifying law degree and a postgraduate diploma. She did not complete a two-year training contract in the UK, the Professional Standards Course, or the vetting and acceptance procedures of the Solicitors Regulation Authority (SRA).

History of Section 15(1)(d) LPA Route to Admission

[17]Guidance on the historical route for admission as a solicitor in the UK can be traced back to the Hansard debate on the Solicitors Examination, &c. Bill. In 18776, Lord Aberdare explained: “LORD ABERDARE, in moving that the Bill be now read the second time, said, its object was to regulate the admission of Solicitors of the Supreme Court of Judicature of England. By former statutes, and by the Acts of 1873 and 1875, persons applying to be admitted as Solicitors were required to pass examinations known as the preliminary, the intermediate, and the final examinations; and the power of making regulations for the conduct of those examinations and of appointing the examiners, was vested in certain of the Judges of the High Court of Justice: the Bill proposed to transfer those powers to the Incorporated Law Society, and make other amendments in the law relating to Solicitors. No person was to be admitted as a Solicitor without a certificate that he had passed the three examinations before stated; these examinations were to be held under the management of the Incorporated Law Society, who were to make all necessary regulations as to time and place and subjects of examination, to appoint the examiners, and arrange their remuneration by fees or otherwise. The fees payable in respect of their examinations were to be settled by the chiefs of the Divisions of the High Court of Justice, and were to be applied to the necessary expenses of these examinations and to other points of legal education. In case of the refusal of a certificate an appeal was given to the Master of the Rolls. Members who had taken University degrees, or had passed certain academical examinations, and utter barristers, who desired to transfer themselves to the other branch of the profession, were excused the preliminary examination. Barristers of five years' standing were exempted from the intermediate examination also, and could be admitted Solicitors on passing the final examination.

[18]The effect of that legislation was to establish the Incorporated Law Society as the sole authority overseeing solicitor qualifications. Admission required passing three examinations: preliminary, intermediate, and final. Certain individuals, such as university graduates, those who had passed other academic examinations, and barristers transferring to the solicitor’s branch, were exempt from the preliminary examination.

[19]By analogy, section 15(1)(d) of the LPA requires that an applicant be not less than 18 years old and “otherwise qualified”. Although the LPA does not define ‘otherwise qualified’, I am of the view that, given the LPA’s origin in pre-independence UK legislation, it should be interpreted in light of historical solicitor qualifications. Thus, at a minimum, a university degree would be required.

[20]The intermediate and final examinations of the Law Society of England (‘the Law Society’) ceased to be administered in 1993, when the Legal Practice Course (LPC) became the new qualification route for solicitors. In my view, the route contemplated by section 15(1)(d) of the LPA was a distinct route based on the former examination structure and did not encompass the modern LPC based qualification framework introduced after 1993. The LPC route is specially provided for in Section 15 (1)(c) of the LPA.

[21]In my view, the route of qualification contemplated by section 15(1)(d) became legally obsolete after 1993, when the intermediate and final examinations of the Law Society of England were discontinued and replaced by the LPC. Although section 15(1)(d) remains on the statute books, legislation must be construed purposively and in the light of legal developments. The reference to a defunct qualification renders this provision incapable of current application. To treat the LPC as a modern substitute for the discontinued examinations would amount to judicial amendment of the statute, an exercise which properly belongs to the legislature.

[22]Additionally, section 15(1)(d) must be read in the context of legal developments since 1993. The qualification pathway under section 15(1)(c), referring to ‘solicitors of the United Kingdom’, reflects the post 1993 regime. As such, the examinations contemplated in section 15(1)(d) no longer exist and no longer constitute a valid route to admission.

[23]Even if I were to accept that the final examinations referred to in section 15(1)(d) are equivalent to the modern LPC, which I do not, and that the Applicant’s LLB and LPC satisfy the requirements for preliminary, intermediate, and final qualifications, she would still have to satisfy the conjunctive requirements in subsection (2) of section 15. That subsection states: “(2) In order to be admitted under subsection (1)(d) a person shall produce to the Registrar certificates of the Law Society of England that he or she has passed the intermediate and final examinations of the said Law Society and shall at the same time produce satisfactory evidence— (a) that he or she served for 5 years continuously in the Chambers of a practising barrister and has throughout that time been of good character; and (b) that he or she has passed one of the following examinations— i. the Matriculation Examination of the University of London, ii. the School Certificate Examination of the University of Cambridge, or iii. any examination prescribed as qualifying for admission to the Inns of Court.”

[24]The highlighted portion above imposes a clear statutory obligation on the Applicant to produce to the Registrar certain specific certificates. To construe the provision in the manner urged by the Applicant would, in effect, alter the legislation and render inoperative an express statutory requirement. To accept the Applicant’s submission would be to amend an Act of Parliament to change the evidential burden to produce specific certificates imposed on the Applicant. In my view, such an approach is impermissible, particularly given that the certificates in question, pertaining to the intermediate and final examinations, are no longer issued.

[25]Apart from the issue of the examinations, there is that of the regulatory body. Counsel for the Applicant has submitted that the SRA functions as an integral constituent entity and/or arm within the institutional framework of the Law Society. The Applicant submits that while the SRA exercises regulatory functions with operational independence, its authority is derived from, and remains subject to, the delegation and framework established by the Law Society pursuant to statutory mandate.

[26]In essence, the Applicant seeks to establish that regulation of solicitors by the SRA is the same as regulation under the Law Society. Thus, Counsel seeks to persuade the Court that not only are the intermediate and final examinations the same as the LPC, but that the SRA and the Law Society are the same regulatory body.

[27]According to Halsbury’s Laws of England7: “398. Admission to the solicitor’s profession – The Solicitors Act 1877 placed the entire practical control of the preliminary examination (introduced by the Solicitors Act 1860) and of the intermediate and final examinations in the hands of the Law Society, and the Solicitors Act 1974 vested complete control over the qualifications for admission as a solicitor in the Society, subject only to the approval by the Lord Chancellor, the Lord Chief Justice and the Master of the Rolls of the Society's training regulations. Under the Legal Services Act 2007, this control was subject to important additional controls, exercised by the Legal Services Board. Under a government initiative, a legal apprenticeships programme leading to qualification as a solicitor was being developed by law firms in conjunction with the Solicitors Regulation Authority and launched in 2016.”

[28]The Legal Services Act 2007 established the Legal Services Board to oversee the regulation of the legal services sector. The Act also provides for ‘approved regulators’, one of them being the SRA. As footnote 2 of Halsbury’s Laws of England8 it is stated: “Legal Services Act 2007 Sch 4 para 1(1) table. Schedule 4 refers to Law Society. However, in practice the body currently responsible for the regulation of solicitors is the Solicitors Regulation Authority (see para 412 et seq). The Solicitors Regulation Authority does not have an independent legal personality, but it is accepted practice for it to sue in its own name. The Solicitors Regulation Authority is an approved regulator in relation to the following reserved legal activities: 1) the exercise of a right of audience; 2) the conduct of litigation; 3) reserved instrument activities; 4) probate activities;

5) the administration of oaths.”

[29]These cited authorities make clear that the Law Society is no longer the approved regulator of solicitors, in practice, although it is referred to in the Act. This understanding is further supported by the Applicant’s references to the Explanatory Memorandum to the Legal Services Act 2007 (The Law Society (Modifications of Functions) Order 2015 at paragraph 7.1) and the SRA’s Governance Handbook, February 2025 edition, pages 1–2, paragraph 2. That is, although it was the Law Society that established the SRA, and the SRA exercises powers under delegated authority governed by the Law Society’s General Regulations, it is the SRA and not the Law Society that in fact exercises these regulatory powers. The SRA is an independent regulatory arm of the Law Society. Therefore, the only logical conclusion to be reached is that the body responsible for regulating solicitors is the SRA and not the Law Society. In my view, the Applicant’s argument on the inextricable nature of the relationship between the SRA and the Law Society of England is misplaced.

Satisfaction of Subsection 15(2)(a)

[30]In her supplemental affidavit filed on 11 April 2025, the Applicant again refers to her admission to practise in Trinidad and Tobago since 2016. She deposes that she is a member of chambers and has been so since 2020. She further deposes that she has served for nine years continuously in the chambers of a practising barrister and, throughout that time, has maintained a reputation for good character.

[31]I am unable to agree with the Applicant that service with a barrister continuously in chambers for five years specified in the LPA, includes service in chambers in Trinidad and Tobago. In my view, the requirement of five years’ service ‘in the chambers of a practising barrister’ must be interpreted in context. The provision appears in legislation intended to regulate admission to practise in Saint Lucia. It follows that the required service must be within this jurisdiction. Had Parliament intended to recognise service in foreign jurisdictions, it would have done so expressly, as it did in section 15(1)(b), which refers to barristers or advocates of the superior courts of ‘any British Possession’. No such wording appears in subsection (2)(a). Moreover, given Saint Lucia’s unique hybrid legal system combining civil and common law traditions, it is reasonable to infer that the legislature intended the practical training to reflect exposure to local legal norms. I do not accept that service anywhere in the Commonwealth or CARICOM would suffice.

[32]The purpose of the requirement is to ensure that a candidate’s experience is relevant to the legal practice in Saint Lucia. Saint Lucia is one of the few jurisdictions with a hybrid legal system, incorporating both civil and common law elements, unlike Trinidad and Tobago, which follows a purely common law system. If the Applicant’s broad interpretation were to be accepted, then theoretically, the five years of service could be completed in any jurisdiction in the world and still qualify. I do not accept that view. The service period must refer to experience in chambers within Saint Lucia.

[33]Assuming I am wrong, and the five years’ service may include time spent working in Trinidad, the Applicant has still not convinced me that her admission and practice in that jurisdiction ought to be considered for the purposes of this subsection. Her evidence is that she worked as an Attorney-at-Law in Trinidad and Tobago alongside a barrister, and that this suffices under subsection 15(2)(a). Her evidence is not that she did a pupilage in Trinidad and Tobago, simply that I ought to consider her time practicing as an Attorney at Law in that jurisdiction as meeting the statutory requirement of a pupilage. I disagree.

[34]The Applicant’s admission to practise law in Trinidad and Tobago was based on section 15(1A) of the Legal Profession Act of that jurisdiction. That section provides a substitute route for nationals of Trinidad and Tobago who hold the LPC, allowing admission after completing a six-month attachment with a local practitioner. The LPA of Saint Lucia contains no such provision. Further, the applicability of that provision to non-nationals has been the subject of significant judicial comment, and it is clear that it does not apply to non-nationals of Trinidad and Tobago. The use of the LPC, whether with or without attachments to chambers, as a qualifying route for admission to these Courts and as a comparative qualification providing an alternative route for admission (in the jurisdiction of Grenada) has been the subject of at least two applications, both of which were refused; See Re: Admission of Dianne Hadeed9 and Re: Admisison of Wayne Hazel Jonathan Patrice10

[35]This Court also notes with concern that the Applicant failed to disclose that her admission in Trinidad and Tobago was the subject of negative judicial comment by the Court of Appeal in that jurisdiction. At the hearing, Counsel for the Applicant indicated that he did not think disclosure of the judgment was relevant to the Applicant’s admission to practise in Saint Lucia. This non-disclosure is one the Court takes seriously. It is my view that the fact of this judgment and the comments made about the Applicant being admitted in error ought to have been disclosed and squarely addressed in her affidavit in support, especially as the Applicant relies on her years of service in chambers in Trinidad and Tobago, in meeting the admissibility criteria.

[36]The Court only became aware of this through its own research on the eligibility of LPC holders for admission in other jurisdictions. I refer to the unanimous judgment of the Court of Appeal of Trinidad and Tobago in Hadeed, where Bereaux JA, at paragraphs 73 and 74, stated: “(73) The respondent also contends that she should have the benefit of being allowed to be admitted to legal practice based on the fact that there were non-nationals who were admitted under section 15(1A) of the LPA. She alleges that this was a ‘practice’ under a previous Assistant Registrar. (74) In agreement with the judge, I say that there was no such practice. The Registrar’s unchallenged evidence was that the admissions of Skeeta John and Janel Lindie were done in error. Since it was done in error and the admissions were ultra vires section 15(1A) of the LPA, it was not proper practice, far less one from which there can be an expectation which is legitimate. The contention is without merit.”

[37]When asked how the Court is to treat a Certificate of Good Standing in light of this Court of Appeal judgment, which is highly persuasive though not binding, Mr. Bristol submitted at the hearing: “My Lord, I'm not able to opine on matters that have not been deemed by the court to cause somebody to not have standing. My client here has the standing of being an advocate of record in Trinidad. Her fees are currently paid. She has a relevant certificate of good standing, my Lord, and in those circumstances, unless somebody brings an action to challenge her status and to challenge her standing in Trinidad, we have to accept that her standing is valid. The comment made in the paragraph of the judgment, 72 and 73 of that Court of Appeal judgment, does not say that she’s disqualified from practice, does not say or create an order saying that she should be removed from the rolls. It made a comment about what appeared to have been a procedural deficiency, but it never said that in any way is she unqualified to practise.”

[38]With great respect to Counsel, I disagree. In my view, a certificate of good standing is an administrative confirmation that an individual remains on the roll and is not subject to disciplinary sanction. It does not and cannot validate an ultra vires admission. The Court of Appeal of Trinidad and Tobago has found, in clear and unambiguous terms, that the Applicant’s admission was done in error and was ultra vires section 15(1A) of the Legal Profession Act of that jurisdiction. While that finding is not binding on this Court, it is highly persuasive. In the face of such a judicial pronouncement, the certificate of good standing is of limited evidential value and cannot override the Court’s assessment of legal ineligibility. I therefore attach very little weight to it.

[39]Even if, as Mr. Bristol and Mr. Prospere contended, the Court of Appeal’s statements were merely obiter, I am of the view that they must be given significant weight. The Applicant’s standing with the Law Association of Trinidad and Tobago has to be read in context with the judicial declaration that her admission was in error.

[40]The Court cannot be expected to recognise or rely on the Applicant’s practice as an Attorney-at-Law in Trinidad and Tobago if she had no legal entitlement to be admitted there ab initio.

[41]The Applicant’s submission that she was not a party to the Hadeed proceedings and that no order was made against her is of no relevance. She was cited as a comparator in a judicial determination on the eligibility of non-nationals under the relevant legislation. The issue before the Court of Appeal was not the Applicant’s qualification, but her legal eligibility for admission under the route she utilised. The High Court held in favour of eligibility; the Court of Appeal reversed that finding. There was no further appeal. I do not accept the submission that the remarks of the Court of Appeal should be given little or no weight simply because the Applicant was not a party to the proceedings.

Satisfaction of Section 15(2)(b) of the LPA

[42]The Applicant submitted that she has passed an examination qualifying for admission to the Inns of Court. I do not agree.

[43]Admission to the Inns of Court is not applicable to solicitors or people holding solicitor’s qualifications. It applies to individuals pursuing a career as a barrister11. Solicitors are not required to be members of the Inns of Court.

[44]There are, however, limited exceptions. As noted in the link provided by the Applicant to the Bar Standards Board, admission to an Inn may be granted where an applicant is: (1) a transferring qualified lawyer, who must nonetheless meet the requirements for admission to the Bar of England and Wales, including passing the Bar Transfer Test (BTT); or (2) seeking temporary admission and call, such as a qualified foreign lawyer with at least three years’ advocacy experience in courts that apply law substantially similar to the common law of England and Wales, in which case they may be called to the Bar for a specific case.

[45]The Applicant has produced no evidence to establish that she has passed the Bar Transfer Test or qualifications under any of the exceptions permitting admission to an Inn of Court.

[46]The Applicant’s submission that her Bachelor of Laws degree is sufficient to meet the requirement for an examination qualifying for admission to the Inns of Court is also incorrect. While the LLB is a necessary academic foundation, admission to an Inn requires either further professional training to become a barrister or meeting the requirements applicable to transferring lawyers or temporary admissions. Simply put, being the holder of a LLB alone does not entitle an application to admission to an Inns of Court. The Applicant has not demonstrated eventually, that she satisfies any of these criteria of becoming a member of an Inns of Court.

FURTHER PROVISIONS:

[47]For completeness, subsections (a) to (e) of section 15(1) are subject to subsection (3) and to section 16 of the LPA. However, neither of these assist the Applicant.

[48]Subsection (3) simply sets out the additional procedural steps required after the applicant has established substantive qualification under any of subsections (a) to (e).

[49]Section 16 applies to non-citizens. It is not applicable in this case, as the Applicant is a Saint Lucian by birth.

CONCLUSION:

[50]For all the foregoing reasons, I hold that the Applicant is not qualified to be admitted to practise law in Saint Lucia under section 15 of the Legal Profession Act.

[51]The Court cannot conclude without noting the devastating effect that this judgment may have on the Applicant. The Court acknowledges the Applicant’s predicament, which evokes the fullest measure of empathy. It is, however, constrained by the current state of the law. There is a pressing need for the Legal Profession Act of Saint Lucia to be reviewed and amended. As the region advances towards greater harmonisation, to the benefit of all jurisdictions, the qualifications for admission to practise law merit urgent reconsideration, with a view to ensuring consistency in eligibility criteria across the Caribbean. It is the Court’s earnest hope that this judgment may serve as a catalyst for that much needed legislative reform.

ORDERS:

[52]For the reasons above, I make the following orders: 1) Pursuant to section 15(4) of the Legal Profession Act, Cap. 4.02, the Court refuses the application of Skeeta Indira Sancheria John to be admitted to practise law in Saint Lucia on the ground that she does not meet the statutory requirements under section 15 of the said Act. 2) The application filed on 1 April 2025 is dismissed. Alvin S. Pariagsingh Judge By the Court, Registrar

THE EASTERN CARIBBEAN SUPREME COURT IN THE HIGH COURT OF JUSTICE CIVIL DIVISION SAINT LUCIA Case Number: SLUHCV2025/0135 IN THE MATTER of Section 15 of the Legal Profession Act. Cap. 2.04 of Revised Laws of Saint Lucia BETWEEN: -and- IN THE MATTER of an application by SKEETA INDIRA SANCHERIA JOHN to be admitted to practise as an Attorney -at- Law in Saint Lucia. SKEETA INDIRA SANCHERIA JOHN Applicant Before the Honourable Mr. Justice Alvin S. Pariagsingh Appearance: Mr. Anthony Bristol and Mr. Leslie K. Prospere for the Applicant1. ————————– 2025: April 14 – hearing April 17 – written submissions April 23 – decision ————————– JUDGMENT Application for Admission to Practise as an Attorney at Law in Saint Lucia pursuant to Section 15(1)(d) of the Legal Profession Act, Cap. 2.04 of the Revised Laws of Saint Lucia.

[1]PARIAGSINGH, J:- Before the Court is an application by Skeeta Indira Sancheria John to be admitted to practise as an Attorney-at-Law in Saint Lucia pursuant to section 15(1)(d) of the Legal Profession Act (‘the LPA’)2. 1 Mr. Leslie K. Prospere filed a Notice of Acting on 17th April 2025 and the submissions ordered by the Court on 14th April 2025. 2 Chapter 2 04 of the Revised Laws of Saint Lucia

[2]Admission to practise is a privilege, even a person who is qualified to practise can be refused admission if the Court is of the opinion that the Applicant is not of good character. In assessing eligibility, the Court must look at all the statutory requirements and not just qualifications; See Layne v Attorney General of Grenada3.

[3]It is also well settled that the discretion to assess and examine applicants as to their learning and qualifications and to admit them to practise has always been exercised by the judiciary and it rest exclusively with the Court to determine who is qualified to become one of its officers; See Re: Admission of Andrew Ian James King, Rhea Harrikissoon and Bilal Mahmad4. FACTS:

[4]The Applicant is a Saint Lucian by birth but currently resides in Trinidad and Tobago. She completed her Bachelor of Laws degree with the University of London and was awarded her LLB on 1 August 2014. She obtained a Certificate of Higher Education and a Postgraduate Diploma from the University of Westminster in October 2015 (the LPC’). She was admitted to practise as an Attorney-at-Law in Trinidad and Tobago on 16 April 2016 and holds a practising certificate for the current law year 2024/2025 in that jurisdiction. She now seeks admission in this jurisdiction pursuant to section 15(1)(d) of the LPA.

[5]In support of her application, in addition to her academic qualifications, she relies on a Certificate of Good Standing dated 12 March 2025 issued by the Law Association of Trinidad and Tobago. In her affidavit in support of her application, she deposes, “… that I possess the professional qualifications and experience to practise law in Saint Lucia.”

[6]There is no issue as to the Applicant’s character as in Layne (supra). In further support of her application, she has also produced a Certificate of Character from the Trinidad [2019] UKPC 11 – affirming the first instance decision of Price – Findlay J (as she then was) delivered on 20 December 2013 and the Court of Appeal decision of Blenman, Michel and Webster, JJA delivered on 15 June 2015. 4 BVIHCV2021/0165/ 0166/ 0178 (unreported) per Ellis J (as she then was) delivered on 19 July 2011. and Tobago Police Service dated 6 March 2025. The Applicant has also paid the requisite fee for admission in Saint Lucia.

[7]This application was assigned to this Court on 7 April 2025. Upon perusing same, the Court had concerns about whether the Applicant met the legal requirements for admission to the Bar of Saint Lucia. Counsel for the Applicant was invited to address the Court on 14 April 2025. Also, by the date of hearing, the Applicant had filed a supplemental affidavit on 11 April 2025.

[8]At the hearing on 14 April 2025, it was clarified that the Applicant was not seeking admission pursuant to section 15(1)(c), the ‘Solicitor’s route’, but rather pursuant to section 15(1)(d), commonly referred to as ‘the historical route’. The Court then gave the Applicant permission to file submissions in support of her application, including specifically on the following two issues: 1) Whether the route for qualification as a solicitor, as set out in section 15(1)(d) of the LPA, continued to exist after 1993 when the Legal Practice Course (LPC) was introduced? and if so, 2) In considering the matters set out in subsection (2) of section 15, how is the Court to treat the Applicant’s evidence of attachment to chambers/ good standing in light of paragraph 74 of the Court of Appeal judgment in The Attorney General of Trinidad and Tobago v Dianne Jhamilly Hadeed5? ISSUES:

[9]The issues which arises in this application is whether the admission route under section 15(1)(d) of the LPA still applies, and if so, whether the Applicant meets the requirements for admission as set out in that provision. 5 Civil Appeal No. P310/2019 (Trinidad and Tobago) (unreported) per Bereaux, Jones and des Vignes JJA delivered on 31 July 2020. ANALYSIS:

[11]Admission is further divided into two categories of applicants: citizens, whose eligibility criteria are set out in section 15 of the LPA, and non-citizens, whose criteria are governed by section 16 of the LPA. The Applicant falls within the ambit of section 15, as evidenced by her affidavit and her Saint Lucian passport exhibited in support.

[10]Saint Lucia has three broad categories of persons eligible to be entered on the Roll as ‘Attorneys-at-Law’: Barristers, Solicitors, and Attorneys-at-Law. All Attorneys at Law are also Notary Royals.

[12]There are five routes to admission set out in section 15(1) of the LPA for citizens of Saint Lucia. Once an applicant satisfies any one of these routes, they are eligible for admission, subject to the additional requirements in subsection (3) and section 16. The five routes are: “(a) any English or Irish barrister-at-law, or any Scottish advocate; (b) any barrister or advocate of any of the Superior Courts of any British Possession where similar privileges are accorded to barristers of the Supreme Court; (c) any solicitor of the United Kingdom or Law Agent admitted to practise in Scotland; (d) subject to subsection (2), any person who, being not less than 18 years and otherwise qualified, shall have passed the intermediate and final examinations of the Law Society of England; or (e) any person of not less than 18 years who has obtained the Legal Education Certificate awarded by the Council of Legal Education.”

[13]Subsections (a) and (e) clearly do not apply to the Applicant, as she is neither an English or Irish barrister nor the holder of a Legal Education Certificate.

[14]Subsection (b) also does not apply. Although Counsel Mr. Bristol submitted orally that Trinidad and Tobago, where the Applicant practises, qualifies as a ‘British Possession’ with a ‘Superior Court’, this point was not developed in the written submissions filed by Mr. Prospere.

[15]In any event, I take a different view. While the Supreme Court of Trinidad and Tobago may historically have been regarded as a Superior Court of a British possession, that characterisation no longer holds. Trinidad and Tobago’s judiciary now functions with full constitutional autonomy, and the Supreme Court of Judicature derives its authority from its own domestic legislation, namely the Constitution and the Supreme Court of Judicature Act. Though the country retains the Judicial Committee of the Privy Council as its final appellate court, that is a matter of sovereign choice, not colonial subordination. Accordingly, the Supreme Court of Trinidad and Tobago cannot be regarded as a ‘Superior Court of a British Possession’ for the purposes of section 15(1)(b) of the LPA.

[16]Subsection (c) does not apply either, as the Applicant is not a solicitor of the United Kingdom, nor a Law Agent admitted in Scotland. She has completed only two of the five steps typically required for admission as a solicitor in the UK: a qualifying law degree and a postgraduate diploma. She did not complete a two-year training contract in the UK, the Professional Standards Course, or the vetting and acceptance procedures of the Solicitors Regulation Authority (SRA). History of Section 15(1)(d) LPA Route to Admission

[19]By analogy, Section 15(1)(d) of the LPA requires that an applicant be not less than 18 years old and “otherwise qualified”. Although the LPA does not define ‘otherwise qualified’, I am of the view that, given the LPA’s origin in pre-independence UK legislation, it should be interpreted in light of historical solicitor qualifications. Thus, at a minimum, a university degree would be required.

[17]Guidance on the historical route for admission as a solicitor in the UK can be traced back to the Hansard debate on the Solicitors Examination, &c. Bill. In 18776, Lord Aberdare explained: “LORD ABERDARE, in moving that the Bill be now read the second time, said, its object was to regulate the admission of Solicitors of the Supreme Court of Judicature of England. By former 6 https://hansard.parliament.uk/Lords%E2%80%8F/1877-05-08/debates/ced0c780-9616-4060-afb5- 232dea916e89/SolicitorsExaminationAndCBill, Solicitors Examination, &C Bill Volume 234: debated on Tuesday 8 May 1877 (No. 52). statutes, and by the Acts of 1873 and 1875, persons applying to be admitted as Solicitors were required to pass examinations known as the preliminary, the intermediate, and the final examinations; and the power of making regulations for the conduct of those examinations and of appointing the examiners, was vested in certain of the Judges of the High Court of Justice: the Bill proposed to transfer those powers to the Incorporated Law Society, and make other amendments in the law relating to Solicitors. No person was to be admitted as a Solicitor without a certificate that he had passed the three examinations before stated; these examinations were to be held under the management of the Incorporated Law Society, who were to make all necessary regulations as to time and place and subjects of examination, to appoint the examiners, and arrange their remuneration by fees or otherwise. The fees payable in respect of their examinations were to be settled by the chiefs of the Divisions of the High Court of Justice, and were to be applied to the necessary expenses of these examinations and to other points of legal education. In case of the refusal of a certificate an appeal was given to the Master of the Rolls. Members who had taken University degrees, or had passed certain academical examinations, and utter barristers, who desired to transfer themselves to the other branch of the profession, were excused the preliminary examination. Barristers of five years' standing were exempted from the intermediate examination also, and could be admitted Solicitors on passing the final examination.

[18]The effect of that legislation was to establish the Incorporated Law Society as the sole authority overseeing solicitor qualifications. Admission required passing three examinations: preliminary, intermediate, and final. Certain individuals, such as university graduates, those who had passed other academic examinations, and barristers transferring to the solicitor’s branch, were exempt from the preliminary examination.

[20]The intermediate and final examinations of the Law Society of England (‘the Law Society’) ceased to be administered in 1993, when the Legal Practice Course (LPC) became the new qualification route for solicitors. In my view, the route contemplated by section 15(1)(d) of the LPA was a distinct route based on the former examination structure and did not encompass the modern LPC based qualification framework introduced after 1993. The LPC route is specially provided for in Section 15 (1)(c) of the LPA.

[21]In my view, the route of qualification contemplated by section 15(1)(d) became legally obsolete after 1993, when the intermediate and final examinations of the Law Society of England were discontinued and replaced by the LPC. Although section 15(1)(d) remains on the statute books, legislation must be construed purposively and in the light of legal developments. The reference to a defunct qualification renders this provision incapable of current application. To treat the LPC as a modern substitute for the discontinued examinations would amount to judicial amendment of the statute, an exercise which properly belongs to the legislature.

[22]Additionally, section 15(1)(d) must be read in the context of legal developments since 1993. The qualification pathway under section 15(1)(c), referring to ‘solicitors of the United Kingdom’, reflects the post 1993 regime. As such, the examinations contemplated in section 15(1)(d) no longer exist and no longer constitute a valid route to admission.

[23]Even if I were to accept that the final examinations referred to in section 15(1)(d) are equivalent to the modern LPC, which I do not, and that the Applicant’s LLB and LPC satisfy the requirements for preliminary, intermediate, and final qualifications, she would still have to satisfy the conjunctive requirements in subsection (2) of section 15. That subsection states: “(2) In order to be admitted under subsection (1)(d) a person shall produce to the Registrar certificates of the Law Society of England that he or she has passed the intermediate and final examinations of the said Law Society and shall at the same time produce satisfactory evidence— (a) that he or she served for 5 years continuously in the Chambers of a practising barrister and has throughout that time been of good character; and (b) that he or she has passed one of the following examinations— i. the Matriculation Examination of the University of London, ii. the School Certificate Examination of the University of Cambridge, or iii. any examination prescribed as qualifying for admission to the Inns of Court.”

[24]The highlighted portion above imposes a clear statutory obligation on the Applicant to produce to the Registrar certain specific certificates. To construe the provision in the manner urged by the Applicant would, in effect, alter the legislation and render inoperative an express statutory requirement. To accept the Applicant’s submission would be to amend an Act of Parliament to change the evidential burden to produce specific certificates imposed on the Applicant. In my view, such an approach is impermissible, particularly given that the certificates in question, pertaining to the intermediate and final examinations, are no longer issued.

[25]Apart from the issue of the examinations, there is that of the regulatory body. Counsel for the Applicant has submitted that the SRA functions as an integral constituent entity and/or arm within the institutional framework of the Law Society. The Applicant submits that while the SRA exercises regulatory functions with operational independence, its authority is derived from, and remains subject to, the delegation and framework established by the Law Society pursuant to statutory mandate.

[26]In essence, the Applicant seeks to establish that regulation of solicitors by the SRA is the same as regulation under the Law Society. Thus, Counsel seeks to persuade the Court that not only are the intermediate and final examinations the same as the LPC, but that the SRA and the Law Society are the same regulatory body.

[27]According to Halsbury’s Laws of England7: “398. Admission to the solicitor’s profession – The Solicitors Act 1877 placed the entire practical control of the preliminary examination (introduced by the Solicitors Act 1860) and of the intermediate and final examinations in the hands of the Law Society, and the Solicitors Act 1974 vested complete control over the qualifications for admission as a solicitor in the Society, subject only to the approval by the Lord Chancellor, the Lord Chief Justice and the Master of the Rolls of the Society’s training regulations. Under the Legal Services Act 2007, this control was subject to important additional controls, exercised by the Legal Services Board. Under a government initiative, a legal apprenticeships programme leading to qualification as a solicitor was being developed by law firms in conjunction with the Solicitors Regulation Authority and launched in 2016.”

[28]The Legal Services Act 2007 established the Legal Services Board to oversee the regulation of the legal services sector. The Act also provides for ‘approved regulators’, one of them being the SRA. As footnote 2 of Halsbury’s Laws of England8 it is stated: “Legal Services Act 2007 Sch 4 para 1(1) table. Schedule 4 refers to Law Society. However, in practice the body currently responsible for the regulation of solicitors is the Solicitors Regulation Authority (see para 412 et seq). The Solicitors Regulation Authority does not have an independent legal personality, but it is accepted practice for it to sue in its own name. The Solicitors Regulation Authority is an approved regulator in relation to the following reserved legal activities: 1) the exercise of a right of audience; 2) the conduct of litigation; 3) reserved instrument activities; 4) probate activities; 5) the administration of oaths.”

[32]the purpose of the requirement is to ensure that a candidate’s experience is relevant to the legal practice in Saint Lucia. Saint Lucia is one of the few jurisdictions with a hybrid legal system, incorporating both civil and common law elements, unlike Trinidad and Tobago, which follows a purely common law system. If the Applicant’s broad interpretation were to be accepted, then theoretically, the five years of service could be completed in any jurisdiction in the world and still qualify. I do not accept that view. The service period must refer to experience in chambers within Saint Lucia.

[29]These cited authorities make clear that the Law Society is no longer the approved regulator of solicitors, in practice, although it is referred to in the Act. This understanding is further supported by the Applicant’s references to the Explanatory Memorandum to the Legal Services Act 2007 (The Law Society (Modifications of Functions) Order 2015 at paragraph 7.1) and the SRA’s Governance Handbook, February 2025 7 (Volume 65 (2020)), para 398 8 (Volume 65 (2020)) para 219 edition, pages 1–2, paragraph 2. That is, although it was the Law Society that established the SRA, and the SRA exercises powers under delegated authority governed by the Law Society’s General Regulations, it is the SRA and not the Law Society that in fact exercises these regulatory powers. The SRA is an independent regulatory arm of the Law Society. Therefore, the only logical conclusion to be reached is that the body responsible for regulating solicitors is the SRA and not the Law Society. In my view, the Applicant’s argument on the inextricable nature of the relationship between the SRA and the Law Society of England is misplaced. Satisfaction of Subsection 15(2)(a)

[34]The Applicant’s admission to practise law in Trinidad and Tobago was based on section 15(1A) of the Legal Profession Act of that jurisdiction. That section provides a substitute route for nationals of Trinidad and Tobago who hold the LPC, allowing admission after completing a six-month attachment with a local practitioner. The LPA of Saint Lucia contains no such provision. Further, the applicability of that provision to non-nationals has been the subject of significant judicial comment, and it is clear that it does not apply to non-nationals of Trinidad and Tobago. The use of the LPC, whether with or without attachments to chambers, as a qualifying route for admission to these Courts and as a comparative qualification providing an alternative route for admission (in the jurisdiction of Grenada) has been the subject of at least two applications, both of which were refused; See Re: Admission of Dianne Hadeed9 and Re: Admisison of Wayne Hazel Jonathan Patrice10

[30]In her supplemental affidavit filed on 11 April 2025, the Applicant again refers to her admission to practise in Trinidad and Tobago since 2016. She deposes that she is a member of chambers and has been so since 2020. She further deposes that she has served for nine years continuously in the chambers of a practising barrister and, throughout that time, has maintained a reputation for good character.

[31]I am unable to agree with the Applicant that service with a barrister continuously in chambers for five years specified in the LPA, includes service in chambers in Trinidad and Tobago. In my view, the requirement of five years’ service ‘in the chambers of a practising barrister’ must be interpreted in context. The provision appears in legislation intended to regulate admission to practise in Saint Lucia. It follows that the required service must be within this jurisdiction. Had Parliament intended to recognise service in foreign jurisdictions, it would have done so expressly, as it did in section 15(1)(b), which refers to barristers or advocates of the superior courts of ‘any British Possession’. No such wording appears in subsection (2)(a). Moreover, given Saint Lucia’s unique hybrid legal system combining civil and common law traditions, it is reasonable to infer that the legislature intended the practical training to reflect exposure to local legal norms. I do not accept that service anywhere in the Commonwealth or CARICOM would suffice.

[33]Assuming I am wrong, and the five years’ service may include time spent working in Trinidad, the Applicant has still not convinced me that her admission and practice in that jurisdiction ought to be considered for the purposes of this subsection. Her evidence is that she worked as an Attorney-at-Law in Trinidad and Tobago alongside a barrister, and that this suffices under subsection 15(2)(a). Her evidence is not that she did a pupilage in Trinidad and Tobago, simply that I ought to consider her time practicing as an Attorney at Law in that jurisdiction as meeting the statutory requirement of a pupilage. I disagree.

[35]This Court also notes with concern that the Applicant failed to disclose that her admission in Trinidad and Tobago was the subject of negative judicial comment by the 9 GDAHCV2022/0263 per Actie J (unreported) delivered on 28 December 2022 10 GDAHCV2025/0003 per Glasgow J (unreported) delivered on 7 April 2025 Court of Appeal in that jurisdiction. At the hearing, Counsel for the Applicant indicated that he did not think disclosure of the judgment was relevant to the Applicant’s admission to practise in Saint Lucia. This non-disclosure is one the Court takes seriously. It is my view that the fact of this judgment and the comments made about the Applicant being admitted in error ought to have been disclosed and squarely addressed in her affidavit in support, especially as the Applicant relies on her years of service in chambers in Trinidad and Tobago, in meeting the admissibility criteria.

[36]The Court only became aware of this through its own research on the eligibility of LPC holders for admission in other jurisdictions. I refer to the unanimous judgment of the Court of Appeal of Trinidad and Tobago in Hadeed, where Bereaux JA, at paragraphs 73 and 74, stated: “(73) The respondent also contends that she should have the benefit of being allowed to be admitted to legal practice based on the fact that there were non-nationals who were admitted under section 15(1A) of the LPA. She alleges that this was a ‘practice’ under a previous Assistant Registrar. (74) In agreement with the judge, I say that there was no such practice. The Registrar’s unchallenged evidence was that the admissions of Skeeta John and Janel Lindie were done in error. Since it was done in error and the admissions were ultra vires section 15(1A) of the LPA, it was not proper practice, far less one from which there can be an expectation which is legitimate. The contention is without merit.”

[37]When asked how the Court is to treat a Certificate of Good Standing in light of this Court of Appeal judgment, which is highly persuasive though not binding, Mr. Bristol submitted at the hearing: “My Lord, I’m not able to opine on matters that have not been deemed by the court to cause somebody to not have standing. My client here has the standing of being an advocate of record in Trinidad. Her fees are currently paid. She has a relevant certificate of good standing, my Lord, and in those circumstances, unless somebody brings an action to challenge her status and to challenge her standing in Trinidad, we have to accept that her standing is valid. The comment made in the paragraph of the judgment, 72 and 73 of that Court of Appeal judgment, does not say that she’s disqualified from practice, does not say or create an order saying that she should be removed from the rolls. It made a comment about what appeared to have been a procedural deficiency, but it never said that in any way is she unqualified to practise.”

[38]With great respect to Counsel, I disagree. In my view, a certificate of good standing is an administrative confirmation that an individual remains on the roll and is not subject to disciplinary sanction. It does not and cannot validate an ultra vires admission. The Court of Appeal of Trinidad and Tobago has found, in clear and unambiguous terms, that the Applicant’s admission was done in error and was ultra vires section 15(1A) of the Legal Profession Act of that jurisdiction. While that finding is not binding on this Court, it is highly persuasive. In the face of such a judicial pronouncement, the certificate of good standing is of limited evidential value and cannot override the Court’s assessment of legal ineligibility. I therefore attach very little weight to it.

[39]Even if, as Mr. Bristol and Mr. Prospere contended, the Court of Appeal’s statements were merely obiter, I am of the view that they must be given significant weight. The Applicant’s standing with the Law Association of Trinidad and Tobago has to be read in context with the judicial declaration that her admission was in error.

[40]The Court cannot be expected to recognise or rely on the Applicant’s practice as an Attorney-at-Law in Trinidad and Tobago if she had no legal entitlement to be admitted there ab initio.

[41]The Applicant’s submission that she was not a party to the Hadeed proceedings and that no order was made against her is of no relevance. She was cited as a comparator in a judicial determination on the eligibility of non-nationals under the relevant legislation. The issue before the Court of Appeal was not the Applicant’s qualification, but her legal eligibility for admission under the route she utilised. The High Court held in favour of eligibility; the Court of Appeal reversed that finding. There was no further appeal. I do not accept the submission that the remarks of the Court of Appeal should be given little or no weight simply because the Applicant was not a party to the proceedings. Satisfaction of Section 15(2)(b) of the LPA

[47]For completeness, subsections (a) to (e) of Section 15(1) are subject to subsection (3) and to section 16 of the LPA However, neither of these assist the Applicant.

[42]The Applicant submitted that she has passed an examination qualifying for admission to the Inns of Court. I do not agree.

[43]Admission to the Inns of Court is not applicable to solicitors or people holding solicitor’s qualifications. It applies to individuals pursuing a career as a barrister11. Solicitors are not required to be members of the Inns of Court.

[44]There are, however, limited exceptions. As noted in the link provided by the Applicant to the Bar Standards Board, admission to an Inn may be granted where an applicant is: (1) a transferring qualified lawyer, who must nonetheless meet the requirements for admission to the Bar of England and Wales, including passing the Bar Transfer Test (BTT); or (2) seeking temporary admission and call, such as a qualified foreign lawyer with at least three years’ advocacy experience in courts that apply law substantially similar to the common law of England and Wales, in which case they may be called to the Bar for a specific case.

[45]The Applicant has produced no evidence to establish that she has passed the Bar Transfer Test or qualifications under any of the exceptions permitting admission to an Inn of Court.

[46]The Applicant’s submission that her Bachelor of Laws degree is sufficient to meet the requirement for an examination qualifying for admission to the Inns of Court is also incorrect. While the LLB is a necessary academic foundation, admission to an Inn requires either further professional training to become a barrister or meeting the requirements applicable to transferring lawyers or temporary admissions. Simply put, being the holder of a LLB alone does not entitle an application to admission to an Inns of Court. The Applicant has not demonstrated eventually, that she satisfies any of these criteria of becoming a member of an Inns of Court. 11 See Halsbury’s Laws of England (Volume 65 (2020), para 771 on the constitution and membership of the Inns of Court. FURTHER PROVISIONS:

[48]Subsection (3) simply sets out the additional procedural steps required after the applicant has established substantive qualification under any of subsections (a) to (e).

[49]Section 16 applies to non-citizens. It is not applicable in this case, as the Applicant is a Saint Lucian by birth. CONCLUSION:

[50]For all the foregoing reasons, I hold that the Applicant is not qualified to be admitted to practise law in Saint Lucia under section 15 of the Legal Profession Act.

[51]The Court cannot conclude without noting the devastating effect that this judgment may have on the Applicant. The Court acknowledges the Applicant’s predicament, which evokes the fullest measure of empathy. It is, however, constrained by the current state of the law. There is a pressing need for the Legal Profession Act of Saint Lucia to be reviewed and amended. As the region advances towards greater harmonisation, to the benefit of all jurisdictions, the qualifications for admission to practise law merit urgent reconsideration, with a view to ensuring consistency in eligibility criteria across the Caribbean. It is the Court’s earnest hope that this judgment may serve as a catalyst for that much needed legislative reform. ORDERS:

[52]For the reasons above, I make the following orders: 1) Pursuant to section 15(4) of the Legal Profession Act, Cap. 4.02, the Court refuses the application of Skeeta Indira Sancheria John to be admitted to practise law in Saint Lucia on the ground that she does not meet the statutory requirements under section 15 of the said Act. 2) The application filed on 1 April 2025 is dismissed. Alvin S. Pariagsingh Judge By the Court, Registrar