Two years on from his failed bid to join the legal profession, a disgraced migration agent made yet another unsuccessful attempt to be admitted.
Chief Justice Chris Kourakis, Justice Tim Stanley, and Justice Judy Hughes of the South Australian Supreme Court refused Ryan Raygan’s application to join the legal profession, citing his misconduct as a migration agent that led to a five-year cancellation of his registration.
Following the receipt of several complaints in late 2017, the Migration Agents Registration Authority (MARA) found Raygan failed to issue statements of service to clients after withdrawing money, provided inaccurate information to the Department of Immigration and Border Protection, and failed to give frank and candid advice to clients.
MARA also determined Raygan displayed a “blatant disregard” for the integrity of the protection visa program and failed his obligations in respect of statutory declarations by knowingly making or witnessing statements that contained duplication and misleading information.
After MARA’s decision, Raygan turned to the Administrative Appeals Tribunal, where he provided false evidence and denied “indisputable evidence” he manufactured claims on behalf of clients “by extracting material from one claim and copying it to another”.
Raygan retrained as a lawyer and applied for admission in August 2022, but the full court found he was not a fit and proper person to practise law because his past conduct was “too closely connected with the duties he would be required to discharge as a legal practitioner, and the behaviour too recent to have been adequately remedied”.
He made the most recent application in November 2024, contending he improved his understanding and insight by completing ethics courses, his work in managing a company that provides NDIS services, his legal work experience, and various character references into his remorse.
Justices Kourakis, Stanley, and Hughes were not satisfied that Raygan had proven he was a “suitable candidate for admission at this point in time”.
“The requirement of fitness and propriety to practise where there is past conduct that is inconsistent with such fitness at some earlier time, is a matter to be determined by reference to the nature and extent of the conduct, its recency, and most importantly, whether the court is satisfied that the person can now demonstrate the insight and character to justify being entrusted to fulfil their duties to the court and to their clients,” the full court bench said in their written reasons.
While the legal ethics courses were “undeniably an appropriate step”, they were not supported by many opportunities to put them into practice.
The bench was also not satisfied in the submission that his conduct as a migration agent could be chalked up to immaturity, particularly given he was an “adult graduate in his forties” when it occurred.
While Raygan asked the court to place “significant weight” on his actions towards gaining insight and demonstrating contrition, Justices Kourakis, Stanley, and Hughes said they had some reservations “as to whether the commitment is as deep as it has been portrayed”.
On several occasions, Raygan explained certain significant matters “in a light that might be interpreted as minimising”, they said.
Justices Kourakis, Stanley, and Hughes noted Raygan had appeared to take “some comfort” in the earlier full court suggestion that its refusal should not be taken as an indication he could not be admitted in future, but the court did not claim “the mere passage of time” was sufficient.
“Time passed since the conduct in question is subordinate to the demonstrated achievement of character that the applicant is willing and capable of discharging the rigorous obligations that attach to the practise of the profession,” they determined.
The case: In the matter of Ryan Raygan [2025] SASCFC 4.
Naomi Neilson is a senior journalist with a focus on court reporting for Lawyers Weekly.
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