Cases2600211/2023

Claimant v General Medical Council

27 June 2025Before Employment Judge S ShoreEast Londonremote video

Outcome

Other

Individual claims

Direct Discrimination(race)not determined

Claim not determined at this preliminary hearing. Tribunal refused respondent's strike-out applications on jurisdiction, time and no reasonable prospects grounds but made a £500 deposit order finding little reasonable prospect of success. Claimant alleges GMC discriminated in how it conducted disciplinary investigations and processes.

Direct Discrimination(sex)not determined

Claim not determined at this preliminary hearing. Tribunal refused respondent's strike-out applications on jurisdiction, time and no reasonable prospects grounds but made a £500 deposit order finding little reasonable prospect of success. Claimant alleges GMC discriminated in how it conducted disciplinary investigations and processes.

Direct Discrimination(race)not determined

Direct race discrimination claim based on alleged less favourable treatment compared to non-Sudanese doctors. Tribunal found claim has little reasonable prospect of success but refused to strike out without hearing evidence. Deposit order made.

Direct Discrimination(sex)not determined

Direct sex discrimination claim based on alleged less favourable treatment. Tribunal found claim has little reasonable prospect of success but refused to strike out without hearing evidence. Deposit order made.

Harassment(race)withdrawn

Withdrawn by claimant at preliminary hearing on 24 April 2023 and dismissed by judgment dated 25 April 2023.

Victimisationwithdrawn

Withdrawn by claimant at preliminary hearing on 24 April 2023 and dismissed by judgment dated 25 April 2023.

Whistleblowingwithdrawn

Detriment for making protected disclosure claim withdrawn by claimant at preliminary hearing on 24 April 2023 and dismissed by judgment dated 25 April 2023.

Facts

Dr Hassaballa, a medical doctor, was investigated by his employer Basildon University Hospital in 2018 (no action) and again in 2021, resulting in an 18-month final written warning in June 2021. He resigned in October 2021. The GMC investigated these 'Trust Matters' and closed them with no action in August 2022. Separately, the GMC opened a 'Dishonesty Matters' investigation in December 2021 when Dr Hassaballa allegedly failed to complete a Work Details Form and later failed to inform a new employer of ongoing investigations. A Medical Practitioners Tribunal found the dishonesty allegations proven in September 2023 and erased him from the register. Dr Hassaballa claims the GMC's conduct of these investigations was discriminatory on grounds of race (Sudanese nationality) and sex.

Decision

The tribunal refused the GMC's applications to strike out on jurisdictional grounds (section 120(7) EqA), time grounds, and no reasonable prospects grounds. The judge found the claims concern procedural conduct rather than appealable decisions, and evidential issues on time and continuing conduct needed full hearing. However, deposit orders of £500 each (£1,000 total) were made on race and sex discrimination claims, finding little reasonable prospect of success due to weak comparators, weak linkage between the two sets of disciplinary matters, and weak explanations. The case proceeds to full hearing.

Practical note

Discrimination claims against regulatory bodies like the GMC concerning investigatory procedure (rather than final decisions) can proceed in the Employment Tribunal despite section 120(7) EqA, but weak comparator evidence and difficulty proving continuing conduct may attract deposit orders even where strike-out is refused.

Legal authorities cited

Uddin v GMC [2013] ICR 793 EATChandhok v Tirkey [2015] IRLR 195Vaughan v Modality Partnership [2021] IRLR 97Abercrombie v Aga Rangemaster plc [2013] EWCA 1148Ali v Office of National Statistics [2005] IRLR 201Transport and General Workers Union v Safeway Stores Ltd UKEAT/009/07Selkent Bus Co v Moore [1996] IRLR 661Cox v Adecco Limited UKEAT/0339/19/ATAli v Office of the Immigration Services Commissioner [2021] ICR 452 EATMichalak v GMC [2017] UKSC 71Khan v GMC [1996] ICR 1032 CAChaudhary v Specialist Training Authority Appeal Panel [2005] ICR 1086 CAIgboaka v Royal College of Pathologists UKEAT/0036/09/SM

Statutes

Medical Act 1983 s.40Equality Act 2010 s.23(1)Equality Act 2010 s.123Equality Act 2010 s.120(7)Equality Act 2010 s.53ET Rules 2013 r.76ET Rules 2013 r.39ET Rules 2013 r.37(1)(a)Medical Act 1983 s.35A(2)

Case details

Case number
2600211/2023
Decision date
27 June 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Name
General Medical Council
Sector
regulator
Represented
Yes
Rep type
barrister

Employment details

Role
Medical doctor

Claimant representation

Represented
Yes
Rep type
barrister