AC-2025-CDF-000062 - [2025] EWHC 2619 (Admin)

On the unimpeachable findings of the MPT, the appellant has limited insight into his wrongdoing. His limited insight is amply demonstrated by the fact that he blames his wife for the criminal proceedings, accusing her of making so many allegations that he found the criminal case “difficult and complex” (appellant’s skeleton argument) and felt that he had to defend himself in court rather than plead guilty (oral submissions).

The appellant’s denial of his offending is not in itself a ground for erasure but the practical effect is that his remediation work has been undertaken on the inadequate basis that he has not been violent to his wife. The appellant relied in particular on a letter from his counsellor, Mr Dale Williamson. The letter states that the appellant had undertaken seven counselling sessions designed to help him make “healthier” decisions. It states that:

“Dr Haroon has used our sessions to explore in depth the emotions and personal experiences associated with the conviction, his understanding of the reasons behind the accusations, the impact of being found guilty, and the ongoing implications for his career.

Through our work, Dr Haroon has made significant progress in developing effective strategies to manage conflict, stress and anxiety. Moreover, he has gained a deeper understanding of how his decisions and behaviours have contributed to his current circumstances.

Dr Haroon has expressed a desire to continue counselling with me indefinitely to further support his mental wellbeing during the GMC investigation and continue exploring the origins of certain behaviours and tendencies, of which he has already developed a comprehensive understanding.”

The appellant criticises the MPT for refusing to give the letter any weight. However, as Mr Anderson submits, Mr Williamson’s letter is vague and does not begin to deal with remediation in the context of spousal abuse. The MPT was entitled to place no weight on it.

The appellant relies on his witness statement and reflective statement as the other principal sources of evidence of insight and remediation. Nothing that the appellant says in these documents can possibly undermine the findings of the MPT that he had not achieved the level of remediation that would be compatible with continued registration.

When asked in cross-examination before the MPT about how the public would perceive the effect of his actions on his wife, he referred primarily to the impact on his own reputation and to all the suffering he had experienced, rather than to the impact on his wife. As Mr Anderson emphasises, his evidence to the MPT damaged rather than enhanced his case that his remediation has been effective.

The appellant told the Tribunal, and has told this court, that he wishes to undertake further remedial work. However, the MPT was not bound to await the outcome of any further work before reaching a decision on sanction. In any event, the MPT was not requested to do so.

These various factors amply justify the MPT’s conclusion that there remained a risk that the appellant would repeat the sort of behaviour that underlay his criminal conviction. The MPT was not wrong to conclude that the appellant’s level of impairment was fundamentally incompatible with continued registration, so that suspension would not have been a sufficient sanction (Guidance, para 92). Applying the test in Sastry, the sanction imposed was appropriate and necessary in the public interest. It was not excessive or disproportionate. Ground 3 is dismissed.