The Supreme Court of India in Harish Chandra Tiwari v. Baiju, (2002), while considering the appropriate…

A monetary penalty equal to double the amount misappropriated is the appropriate sanction under the Act.

Reprimand is the appropriate punishment for a first‑time misappropriation, since removal from the roll would be disproportionate.

Suspension from practice for a period of five years is the standard sanction for misappropriation of client funds.

Misappropriation of a client’s money constitutes one of the gravest forms of professional misconduct and ordinarily warrants removal of the advocate’s name from the State roll.