Cases3301580/2023

Claimant v General Medical Council

17 July 2024Before Employment Judge L BrownCambridgein person

Outcome

Other

Individual claims

Victimisationnot determined

Claimant alleged that the creation, maintenance and refusal to amend Annex A (a critical record on his GMC file) was victimisation due to his prior protected acts (raising discrimination complaints in 2011, bringing ET claims in 2012). Tribunal found this was fact-sensitive, requiring full hearing to determine motivation of decision-makers and whether maintenance of Annex A was victimisation or straightforward policy application. Strike-out application dismissed.

Indirect Discrimination(race)not determined

Claimant alleged that GMC's PCPs (publishing advice on record, failing to remove it, thereby putting BME doctors at disadvantage) indirectly discriminated against him as BME doctors more likely to be disciplined and disadvantaged by prejudicial information. Tribunal found claims fact-sensitive, requiring evidence from Respondent on whether maintaining Annex A was proportionate means of achieving legitimate aim. Strike-out application dismissed.

Facts

Dr Adams, a BME emergency medicine consultant, was dismissed by Kettering General Hospital in 2012 after raising concerns about racial bias and management. He brought ET claims in 2012 which settled. The GMC investigated him and in February 2013 published 'Annex A' on his register containing critical comments about his professional conduct based on information from KGH and his subsequent employer NLAG, which did not renew his contract. Annex A remained on his GMC record for over 10 years. In 2022, Dr Adams requested the GMC amend or remove Annex A, arguing it contained prejudicial material that prevented him obtaining long-term NHS employment. The GMC refused. He brought claims of victimisation and indirect race discrimination against the GMC.

Decision

The tribunal dismissed the GMC's strike-out and deposit order applications. It found: (1) it had jurisdiction as no statutory appeal existed against the GMC's administrative decision to maintain Annex A; (2) the claims did not have no/little reasonable prospect of success as they were fact-sensitive, requiring full hearing of evidence on the GMC's decision-making, whether there was any discretion to amend records, and whether maintaining Annex A was victimisation or legitimate regulatory practice; (3) limitation issues also fact-sensitive and reserved for final hearing, though part of claim found to be in time from September 2022 onwards.

Practical note

Administrative decisions by professional regulators to maintain adverse information on practitioner records may be challengeable as discrimination even where the regulator has statutory duties, particularly where the decision-making processes, discretion available, and proportionality of maintaining such records require factual investigation that cannot be determined at preliminary hearing.

Legal authorities cited

Anyanwu v South Bank Student Union [2001] ICR 391GMC v Michalak [2018] ICR 49 (UKSC)Mr Sanwar Ali v Office of the Immigration Services Commissioner UKEAT/0271/19/VPKhan v General Medical Council [1996] ICR 1032 (CA)Dr G Igboaka v Royal College of Pathologists UKEAT/0036/09/SMDr M Uddin v GMC & Ors UKEAT/0078/12/BACox v Adecco [2021] ICR 1307 (UKEAT)Balls v Downham Market [2011] IRLR 217 (UKEAT)Ezsias v North Glamorgan NHS Trust [2007] ICR 126 (CA)Hemdan v Ishmail [2017] ICR 486 (EAT)Robertson v Bexley Community Centre [2003] IRLR 434Hendricks v Metropolitan Police Commissioner [2003] ICR 530Sharma v New College Nottingham EAT 0287/11Javed v Blackpool Teaching Hospitals NHS Foundation Trust EAT 0135/17Sami v Avellan [2022] EAT 72

Statutes

Equality Act 2010 s.53Equality Act 2010 s.54Equality Act 2010 s.120Equality Act 2010 s.120(7)Medical Act 1983 s.25Medical Act 1983 s.28-29Medical Act 1983 s.35B(1)(b)Medical Act 1983 s.38Medical Act 1983 s.40GDPR Article 6

Case details

Case number
3301580/2023
Decision date
17 July 2024
Hearing type
preliminary
Hearing days
1
Classification
procedural

Respondent

Name
General Medical Council
Sector
regulator
Represented
Yes
Rep type
barrister

Employment details

Role
Consultant in Emergency Medicine
Service
1 years

Claimant representation

Represented
Yes
Rep type
barrister