The High Court has allowed an appeal brought by the Professional Standards Authority for Health and Social Care (PSA) against a sanction imposed by the General Dental Council (GDC) in a fitness to practise case involving a dentist found guilty of serious misconduct.
In Professional Standards Authority for Health and Social Care v The General Dental Council & Anor [2026] EWHC 1603 (Admin), handed down on 26 June 2026, the Administrative Court quashed a six-month suspension order and remitted the case to a differently constituted Professional Conduct Committee to reconsider the appropriate sanction.
The case arose from proceedings before the GDC’s Professional Conduct Committee, which considered allegations relating to the conduct of a senior dentist towards junior female colleagues between 2020 and early 2023. Following a 12-day hearing, the Committee found that the dentist had engaged in a sustained pattern of misconduct. The findings included repeated sexually inappropriate comments and questions, sexually suggestive remarks, unwanted physical contact found to be sexually motivated, discriminatory and racist comments, and demeaning behaviour towards women. The Committee concluded that the dentist’s fitness to practise was impaired and imposed a six-month suspension order.
The PSA appealed under its statutory powers, arguing that the sanction was insufficient to protect the public interest. It did not challenge the Committee’s findings of fact but contended that the Committee had failed to reflect adequately the seriousness of the misconduct, had given excessive weight to mitigating factors, and had not properly applied the GDC’s sanctions guidance. The PSA submitted that the Committee had failed to provide adequate reasons for concluding that erasure from the register was not required.
Allowing the appeal, the High Court held that the Committee had erred in its approach to sanction. The Court found that the Committee’s reasoning did not adequately justify the six-month suspension in light of the sustained pattern of sexualised, discriminatory and abusive conduct that it had found proved. The Court concluded that the deficiencies in the Committee’s reasoning meant that the sanction could not stand.
The Court quashed the suspension order and remitted the matter to a differently constituted Professional Conduct Committee for a fresh determination of sanction in accordance with its judgment.
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