The Changing Threshold for Regulators’ Challenges to Impairment and Sanction – R (GMC) v Anjum [2026] EWHC 1688 (Admin) – 2 Hare Court
‘Appeals against the decisions of regulators, whether pursued by the professional or by the regulating body, are unpredictable affairs. Given the near-infinite variety of factual circumstances, it is difficult to lay down legal rules. So tribunal decisions on facts are “virtually unassailable” [Southall], but that should not be taken to mean “practically impossible” [Byrne] and appeal courts will “correct material errors of fact and law” [Jagjivan]. Whereas decisions on sanction attract respect with “particular force” [Fatnani], although “there may be matters such as dishonesty or sexual misconduct where the court is likely to feel that it can assess what is needed …” [Jagjivan again].’
2 Hare Court, 13th October 2026
Source: www.2harecourt.com

