Counsel – Disciplinary proceedings. The five-person tribunal which had determined disciplinary proceedings concerning the appellant unregistered barrister had had jurisdiction to deal with the matter, as the provisions for the constitution of a panel in reg rE60 of the Complaints Regulations were clearly procedural requirements that did not, if breached, mean that a panel had no jurisdiction. The Divisional Court, in dismissing the appellant's appeal, further held that fact that the appellant's case had been dealt with by a panel of five, rather than three, had not been unfair to her and unjust.