High court replaces erasure with suspension in dental regulator case

The High Court has allowed an appeal by a claimant dentist against a decision of the General Dental Council (GDC) to remove her from the professional register.

In Grzelczak v General Dental Council [2026] EWHC 890 (Admin), judgment was handed down on 17 April 2026 in the Administrative Court.

The claimant dentist had previously been found by a Professional Conduct Committee of the GDC to have committed serious professional misconduct. The committee directed that her name be erased from the dental register.

The claimant dentist appealed that decision under the statutory framework governing dental regulation. The appeal focused on the appropriateness of the sanction imposed, rather than the underlying findings of misconduct.

In its judgment, the High Court concluded that the tribunal’s approach to sanction was flawed. The court found that the committee had misapplied the GDC’s Sanctions Guidance and had failed to identify or explain perceived deficiencies in the claimant dentist’s remediation.

The court also found that the committee’s assessment of proportionality was not supported by the evidence. It noted that there was evidence of remediation, a reduced risk of repetition, and no identified risk of serious harm, although the claimant dentist was found to have demonstrated only limited insight into her misconduct.

The court held that, in those circumstances, the sanction of erasure was excessive and disproportionate.

Allowing the appeal, the High Court substituted a direction that the claimant dentist’s registration be suspended for a period of six months. The suspension is to be subject to a review hearing at which the matters identified in the judgment are to be addressed.

The decision replaces the original order of erasure with a time-limited suspension under regulatory supervision.

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