ギター弾きの「行政書士開業準備中」

弁護士資格ないのに示談交渉、行政書士を告発

ニュースを知っておられる方は、これについて気になっておられる方もおられるかと思います。

本件については、今後の行政書士の職域に大きな影響が出るかもしれないので、現時点(4月17日時点）でわかっている範囲で検討しておこうと思います。


行政書士を応援くださる方はポチお願いします。

まず、ニュース記事では「行政書士は２００８年１２月～０９年１月、大阪府内の女性から電話やメールで夫の不倫を巡る相談を受け、相手の女性に慰謝料を請求したり、和解を勧めたりし、依頼者から報酬を受け取っていた」とあります。

当然、この内容では100%弁護士法違反であり、ニュースを見た時点では、僕も「また、業際を無視した行政書士が告発されたか」程度に思いました。

事件の事実は明らかではありませんが、とあるコミュニティ内で事件報道直後にご本人が説明された部分を、（本人の主張される）事実を多くの行政書士に知ってもらうためにも引用します。（ただし、実名などをまだ明かすことが不適切であると判断し、引用元は現在のところ示しません）

-以下引用-

私は弁護士法については細心の注意を払い、

・書面は代書にとどめる、
・交渉の窓口にはならない
・慰謝料の算定はしない
・調停、裁判手続きの相談は答えない
・内容証明郵便送付相手が拒否の意思表示をした場合は、それ以上は介入しない

など気を付けて業務を行ってきました。

-引用終り-

尚、他にも詳細な説明として

1.内容証明を書面代理人として、作成・送付の代行（慰謝料などを依頼人が決定する際に個別具体的な事情に踏み込まず、一般論として参考価格を掲示）。

2.相手方より慰謝料の支払いを分割でする旨と公正証書の作成に同意する回答が依頼者宛てに届いたことから、公証役場への手続きの進行、文面の作成を代行するため準備（双方へ委任状を送付）

3.相手方から返送が来ないため、公正証書作成手続きを進める当事者として相手方に「公正証書作成手続きを進めるか？進めないか？」を質問する書面を送付（つまり、依頼者の代理人としての立場などではなく公正証書作成の代理をしても良いかを確認）

ポイントは3以後、なぜか相手方が弁護士に相談し、同弁護士が「弁護士法違反」を根拠に警告文を送ってきたことです。
事件の経緯としてはこれに対して、当行政書士が同弁護士を脅迫と名誉棄損で刑事告訴したために、大阪弁護士会が告発することになったわけです。


一応、個人的なイチ行政書士ブログとして見解を書いておきますと、1～2に弁護士法違反のおそれはないと判断します。つまり弁護士からの警告文は「的外れ」であるか、または「プレッシャーによる早期事件解決を意図的に狙ったもの」であると考えられます。

ただし、事件のトータルな観点でみますと、相手方は表面上は「慰謝料の支払いを分割でする旨と公正証書の作成に同意する回答」をしたわけですが、これは弁護士に相談するための時間稼ぎであったか、回答後に考え直した（気が変わった）ために、弁護士に相談したのではないでしょうか？（つまり、この時点で合意はなくなり、法律紛争性を帯びてきた状態に突入）

その点、当行政書士は警告があった時点で、紛争性の発生を意識し、依頼人への説明と弁護士の紹介あるいは本人による応対を促すべきであり、同弁護士への反駁については
「当事務所対応としては、細心の注意をもって業務にあたったものであり、弁護士法に抵触する業務はまったく行なっていないと解釈しておりますゆえ、警告される覚えはありません。しかしながら、本件について相手方が貴弁護士に相談した事実をもって、相手方の示した前回答は撤回したものとみなし、紛争性を帯びたことを確認した上で只今以降、行政書士としての業務受任を解除することをお伝えいたします。」等と返事するべきであり、これを脅迫と名誉棄損で刑事告訴したことは、まずかったと思います。

なぜならば、行政書士の職務としては（僕の考えではですが）、紛争を未然に防ぐこと、あるいは合意ある案件に限定し、法的書類作成代理を行なうことですので、依頼人のことを最優先するならば、むやみに刑事告訴などをして事を荒立てることはないはずだからです（これはカバチにおいて主人公の田村くんが行なういきすぎた正義感に近いものを感じます）。←行政書士としてのプライドよりも依頼人の利益を最優先すべきだったのではないか？

ただ、弁護士法違反に関する大阪弁護士会の告発やニュース・報道に関しては、まったく「的外れ」なものであり、もし当行政書士が裁判所において、職域を明確にするために最高裁まで争うといわれるのならば、頑張って頂きたいと思いますし、僕も個人的に何らかの賛同はしたいと思っております。

ですが、当ブログを見られている行政書士の皆様におきましては、くれぐれも受任業務に関し、第三者弁護士が介入し、「プレッシャーによる早期事件解決を意図的に狙ったもの」であったとしても弁護士法違反をちらつかせてきた場合は、極力穏便に対処されるべきであり、決して攻撃的にならないようにしてください。
弁護士法を遵守し、業務にあたられている限り、それら弁護士等の行なう警告は「いやがらせ」以外のなにものでもありませんが、しかしながら実際に法律の解釈がグレーであり、裁判例が蓄積されていない以上、立場は明らかに行政書士の方が不利であり、「言ったもん勝ち」なのも事実です。

本事件については、今後行政書士の職域について重要な意味を持つと考えられますので、以後も随時フォローしていく予定です。


もっと行政書士情報を！と思われた方はポチお願いします。

この前はコメントありがとうございました。
非常に参考になりました。

鳥取の事件ですが、事件そのものは知っていたものの、ここまで奥があったとは知りませんでした。

確かに告訴はやりすぎですが、当人の気持ちも分からなくはない気がします。（警告によっぽどひどい文章が書かれていたのかもしれませんね。）
先日行政書士の重鎮と話す機会があったのですが、弁護士会の告発は結構からぶりに終わってるんだよとのことでした。
本人の事実が本当なら、検察側も妥当な判断におちつかせることでしょう。そうなるといいと思います。
それにしても腑に落ちないのは、なぜこの場合に弁護士会が出てくるのだ？ということです。
弁護士が自分自身で告発状を出せば済んだ話です。
また、たとえ弁護士会として問題だと判断したとしても、相手が行政書士一個人のうえに、グレー部分がある事案はいちいち公表すべきではないと思います。
あまりにも正論すぎますか（笑）

あと、
・調停、裁判手続きの相談は答えない
とありましたが、私は
「手続きの仕方一般論をお伝えする限りでは問題ないが、具体的にどう書面を書くかなどを答えることはもってのほか」
という認識でいます。
まあ「内容証明書いてみますけど、相手が承諾しなけりゃ最終的には少額訴訟になりますよ。その際はこの内容証明持って簡易裁判所に行って係員の人の指示に従ってくださいね。」というくらいなんですが。
これは以後やめた方がいいでしょうか？

>>・調停、裁判手続きの相談は答えない

う～ん、一般論でもダメとなると離婚カウンセラーはほとんど非弁じゃないでしょうか・・

＞さとさん
いつもコメントありがとうございます(^^)/
おっしゃるとおり、確かに弁護士会の告発や講義はからぶりに終わっています。
しかし、それは当の弁護士会も百も承知の上で、目的はあくまで、多くの方に「行政書士はこういう業務を受けることができないのですよ」とミスリードさせることなのではないでしょうか？
そして実際に弁護士法違反を犯している行政書士も増加しているわけですから、嘘から出たマコトじゃありませんが、やはり行政書士側が法令遵守し、行政書士会が会員に積極的な指導をしなければならないと思います。
ヘタをすると本当に職域が縮小しますので・・・

尚、調停・裁判手続きについてですが「内容証明書いてみますけど、相手が承諾しなけりゃ最終的には少額訴訟になりますよ。その際はこの内容証明持って簡易裁判所に行って係員の人の指示に従ってくださいね。」というのはオッケーです。
むしろ、このような相談（自分の事例が行政書士に相談すべきなのか、司法書士に相談すべきなのか、弁護士にすべきなのか、裁判所に行き自分自身で書けるのか等）に応じることまでが行政書士の職務であり、いわゆる相談には応じれません。
その点で本行政書士の「調停、裁判手続きの相談は答えない」という意識は的を射た正しいものだと思います。ここで言う調停、裁判手続きの相談とは個別具体的なものを指しているからです。
細かいことですが、さとさんの出された模範解答は「調停、裁判手続きの相談」ではなく「離婚手続きに関する相談」というニュアンスなので（弁護士会はコレすらNGと言いたいようですが・・）

＞misaさん
一般論として慰謝料の相場や、上記にあるようなどの機関を利用すれば良いかなど答える分にはオッケーかと思いますので、行政書士の業務に支障はありません。
しかし、おっしゃるような離婚カウンセラーは個別具体的な回答もされているようですので、かなりグレーです。この件については以前に当ブログでも触れております。
http://blog.gyoseihoumu.com/index.php?e=31#more
もちろん、それぞれのカウンセラーの倫理の問題なので離婚カウンセラーすべてがダメという意味ではありませんが、行政書士よりもグレー度は高いかと思います。
同じ理由でファイナンシャルプランナーの業務も税理士法に抵触する可能性が極めて高いグレーな業務があります。

初めまして！
いつも興味深い記事、参考にさせてもらってます。

この件、ついに逮捕されてしまいました。

特捜部が動くってずいぶん極端だなぁとおもいます。今は、起訴されないことを願うばかりです。

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