To achieve success in counseling, however, the kind of theories and approaches used in by the counselor is very important. The decision on how to combine or handle various theories and approaches is also very important. This paper, therefore, seeks to analyze the different approaches and their manipulative use at the hands of counselors. Comparing counseling to clinical psychology, the Graduate School Planning and Information (2009) explain that “Counseling psychologists focus more on the psychologically healthy individual where clinical focuses on individuals with serious mental illness (e.g. schizophrenia).” This means that counseling is the practice of providing professional service to the psychologically healthy individuals in helping them understand the causes of their problems and give them step by step guidance to go through their problems in making good and informed decisions. The term ‘healthy individual’ used in this explanation means counselors provide their services to the mentally able. This also separates the work of the counselor from the psychiatrist and clears a counselee as being mentally disabled. Counseling approaches come in different forms. This is confirmed by the Indiana Professional Psychological Services (2003) who state that “there are literally hundreds of counseling approaches - ranging from basic active listening and a solution focus - to the seemingly bizarre.” Because of this, counselors generally have the freedom to choose which approach to use at which time for which person. Notwithstanding this, I am of the opinion that counselors should not be limited to any one approach. In other words, counselors should not adapt themselves to only one counseling approach.