John In Accounts: The PM Law Sanction That Doesn’t Add Up

Disproportionate punishment is a phrase that gets thrown around too easily in regulatory debates, but in the case of PM Law’s former financial head, Jonathon Bostock, it genuinely deserves interrogation. His disqualification from working in any SRA‑regulated firm is framed as a necessary response to fabricated bank balances and misleading information.  Bostock was also ordered to pay £1,350 in costs.

Yet when you examine the context, the regulatory inconsistencies, and the structural failures surrounding PM Law’s collapse, the punishment begins to look less like targeted accountability and more like a convenient lightning rod for a much wider institutional breakdown.

Why the PM Law disqualification looks disproportionate

Bostock, is not a Solicitor, but a Chartered Accountant.

The SRA said its wider investigation is "ongoing".

The Solicitors Regulation Authority’s decision to ban Bostock from the profession rests on three pillars: fabricating bank balances, failing to report financial distress, and allowing improper withdrawals from client accounts. On paper, these are serious breaches. But proportionality requires us to ask a deeper question: was the punishment aligned with the scale of his personal culpability, or was it shaped by the scale of the firm’s collapse?

1. PM Law’s collapse was systemic, not individual

PM Law did not fail because of one accountant. It failed because of a long‑term structural insolvency, aggressive acquisition strategies, and a business model that relied on high‑volume conveyancing with razor‑thin margins. The firm’s owners pursued expansion at a pace that outstripped financial stability. They allowed client account shortages to accumulate over years. They failed to implement robust internal controls. They ignored warning signs that any competent board should have acted upon.

Against this backdrop, Bostock’s misconduct, while serious, was surely not the root cause of the £39.5m client account deficit.

It was a symptom of a failing governance structure.

2. The SRA’s approach to non‑solicitors is inherently harsher

Under s.99 of the Legal Services Act 2007, the SRA can disqualify non‑solicitors directly, without the procedural safeguards of the Solicitors Disciplinary Tribunal. This creates a two‑tier system:

• Solicitors receive a full hearing, representation, and a judicial process.

• Non‑solicitors can be banned through an administrative decision.

This disparity matters. Bostock, as a chartered accountant, was subject to the harsher route. The SRA could act quickly, decisively, and without external scrutiny. That speed is often mistaken for severity, but in reality it reflects a structural imbalance: non‑solicitors are easier to punish.

Proportionality demands consistency. Yet the SRA routinely appears to treat behavioural misconduct by solicitors, including harassment, criminal convictions, and breaches of court orders, with far more leniency and procedural caution than financial misconduct by non‑solicitors.

The result is a regulatory landscape where who you are matters more than what you did.

3. The SRA’s need to demonstrate action after a high‑profile failure

PM Law’s collapse was catastrophic. Thousands of clients were left in limbo. The SRA will have to pay millions from the compensation fund. Public confidence in the legal profession has taken another battering.

In such moments, regulators face pressure to show decisive action. A disqualification is a visible, headline‑friendly sanction. It signals that the regulator is “doing something”.

But proportionality requires resisting the temptation to punish individuals more harshly simply because the public demands accountability.

The SRA’s own report acknowledges that PM Law’s financial problems were longstanding and multifaceted. Yet the punishment focuses narrowly on Bostock’s conduct, without addressing, for now, the systemic failures of the firm’s leadership, governance, and risk management.

4. Fabricating balances is serious — but context matters

The SRA emphasised that Bostock provided misleading bank balances. That is undeniably wrong. But context matters:

• The leadership was aware of the shortages.

• The firm had been operating in financial distress for years.

• The pressure to “keep the doors open” was immense.

In failing organisations, individuals often make poor decisions under pressure, not out of malice but out of desperation. Proportionality requires distinguishing between deliberate fraud for personal gain and misguided attempts to keep a failing business afloat.

There is no suggestion that Bostock personally benefited financially. There is no allegation of theft. There is no evidence of personal enrichment.

5. The sanction ignores shared responsibility

PM Law’s directors, owners, and senior managers seemingly all played a role in the firm’s collapse. Yet, the SRA’s decision focuses on the financial head because his misconduct was easiest to evidence - not because it was the most culpable.

The perception is one of decisive action while leaving deeper governance failures still unaddressed.

Conclusion

The disqualification of PM Law’s financial head is not unjustified but it is disproportionate. It reflects structural inconsistencies in the regulatory framework, public pressure after a high‑profile collapse, and a tendency to punish the most visible individual rather than the most responsible collectively.

True proportionality would require a broader, more balanced approach to accountability, one that recognises systemic failure rather than isolating one person.

Thoughts?