A firm of solicitors had acted dishonestly when giving an undertaking to another firm of solicitors. As a result its professional indemnity insurers were not liable to indemnify the firm in respect of a claim brought against it to enforce the undertaking. Both partners had deliberately told lies with the prospect of financial gain or had condoned each other’s dishonesty. Moreover, the firm had only been retained for the provision of the undertaking and for no other purpose. The claim had not therefore arisen from the provision of services in private legal practice as solicitors as required by the policy (Halliwells v NES Solicitors and Quinn Direct Insurance Ltd (2011) EWHC 947 (QB)).