High Court upholds erasure of doctor over serious sexual misconduct

In a judgment handed down on 20 November 2025, the High Court dismissed the appeal of a doctor — the appellant in Sadiq v The General Medical Council — and upheld his erasure from the medical register following findings that his fitness to practise was impaired by serious sexual misconduct.

The case stems from events in November 2020, when the doctor met a woman (the “Complainant”) via a dating app. According to the Complainant’s evidence, after consensual kissing, the doctor digitally penetrated her without consent, applied pressure to her neck, exposed himself, and directed physical contact. The doctor admitted sending inappropriate messages but denied the remaining allegations. 

The relevant hospital referred the matter to the regulator (the General Medical Council — GMC), which culminated in a hearing before a Medical Practitioners Tribunal (MPT) in 2023. After live testimony, the Tribunal found that the doctor had exploited his professional status to gain the Complainant’s trust, and had committed a series of non-consensual sexual acts. It concluded that erasure from the register was necessary to protect public confidence in the medical profession.

The appeal: grounds raised by the doctor

On appeal, the doctor challenged the decision on multiple fronts:

• Argued that procedural safeguards were inadequate: his counsel was prevented from properly cross-examining the Complainant, particularly in light of her autism diagnosis and required support measures. 

• Contended that limitations on closing submissions, and certain questioning, were unfair.

• Challenged factual findings — pointing to alleged inconsistencies between the Complainant’s accounts (e.g. whether she was standing or kneeling), and between her “freeze response” and earlier statements of resistance. 

• Argued the omission of a “Reflections” document from the Tribunal bundle breached fairness; and touched on potential contamination or collusion through third-party communications and social media. 

• Raised additional complaints about technical interruptions during the remote hearing (camera disconnection), missing mitigation material, and the admittance of further documents on appeal. 

In rejecting the appeal, the Court held that — although two procedural imperfections occurred (omission of the Reflections document and a brief video-chair disconnection) — these did not materially affect the fairness of the hearing or its outcome. 

On the cross-examination complaints: while counsel’s questioning was sometimes interrupted to accommodate the Complainant’s vulnerabilities under Rule 36 (GMC Fitness to Practise Rules), the Court found those interventions “proportionate” and within the Tribunal’s protective duty; cross-examination spanned 84 pages and addressed all relevant issues. 

Regarding the factual challenges: applying precedent relating to appellate review of primary findings of fact, the Court emphasised that a tribunal’s credibility assessments — especially on live evidence and vulnerable witnesses — are “virtually unassailable” absent objective error. The Court found the holistic approach (taking into account messaging, contemporaneous behaviour, and early disclosures told to friends) was open to the Tribunal and within a “generous ambit” of reasonable findings. 

On the omitted “Reflections” document: the Court accepted it as a minor procedural irregularity, but held it immaterial — the document addressed only admitted inappropriate messages, not the core non-consensual acts. –

Finally, the Court concluded that the Tribunal’s sanction of erasure was appropriate and proportionate. Given the serious breach of trust and the non-consensual sexual misconduct, mere suspension would not sufficiently protect public confidence in the medical profession.

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