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

The MPT was rightly concerned with public confidence (which is the correct term – rather than public perception). It was held in Bijl (at para 13) that “public confidence in the profession… should not be carried to the extent of feeling it necessary to sacrifice the career of an otherwise competent and useful doctor who presents no danger to the public in order to satisfy a demand for blame and punishment.” It is unrealistic to contend that the appellant’s career has been sacrificed to satisfy a demand for blame and punishment.

Nor can it be said that the MPT was unduly concerned with public confidence at the expense of the appellant’s career. As emphasised in Ibrahimv GMC [2022] EWHC 2936 (Admin), paras 27-30, the Guidance states at para 56 that conduct in a doctor’s personal life may lead to a serious sanction on grounds of public confidence when it relates (among other things) to misconduct involving violence.

By way of cogent example of how public confidence may be damaged, the Tribunal found that permitting the appellant to remain registered as a doctor would convey to the victims of spousal abuse that there might be risks in reporting their own personal circumstances to a doctor as a trusted professional (see para 40 above). In any event, the MPT found that all of the three elements of the overarching objective were engaged in the present case so that its conclusions as to sanction did not rest only on public confidence. Ground 2 fails.