Lawyer, Tuisa Tasi Patea, was chastised for his work as defence lawyer for recently-convicted Romanian fraudster, Catalin Raazvan, the Samoa Observer reports.
Raazvan was found guilty on dozens of charges related to his use of counterfeit cards to steal money from Bank South Pacific automated teller machines (ATM) in Samoa.
But the district court judge, Alalatoa Rosella Papali'i, took issue with the way the lawyer, who is a former Member of Parliament, presented evidence.
After the accused opted not to testify during the trial, the lawyer proceeded to introduce evidence in the summary stage.
Justice Alalatoa said she had never come across the practice of presenting evidence "through the back door" in her many years of service.
She said the court would not tolerate "unethical practice" and warned she was considering referring the matter to the Samoa Law Society.
Meanwhile, it has emerged that Raazvan was also accused of fraud at ATM machines in Vanuatu and Tonga before being convicted in Samoa.