R (Glawdys Leger) v Secretary of State for Education [2025] EWHC 665 (Admin)
Summary
The Professional Conduct Panel (PCP) found Leger guilty of unacceptable professional conduct for making inappropriate comments about LGBTQ+ issues during a class. The Secretary of State accepted the PCP’s recommendation not to issue a prohibition order but to publish the finding of misconduct. Leger challenged this decision on several grounds, including the context of her comments, fairness, and compatibility with her rights under Articles 9 and 10 of the European Convention on Human Rights (ECHR).
The court found that the PCP considered the context of Leger’s comments, which were made during a Religious Studies lesson in a Church of England school. The PCP’s findings were based on evidence, including Leger’s own witness statement, and were not procedurally unfair.
The court held that while the statutory duty to provide a broad and balanced curriculum lies with schools, teachers are expected to deliver it. Leger’s refusal to teach certain curriculum segments was contrary to the school’s policy.
The court found that the interference with Leger’s rights was prescribed by law and proportionate. The PCP and Secretary of State correctly applied the proportionality test, balancing Leger’s rights with the public interest.
The court concluded that the publication of the decision, including Leger’s name, was lawful and proportionate. It served the legitimate aims of maintaining public confidence in the teaching profession and safeguarding pupils.
The claim for judicial review was dismissed.
The court found that the PCP considered the context of Leger’s comments, which were made during a Religious Studies lesson in a Church of England school. The PCP’s findings were based on evidence, including Leger’s own witness statement, and were not procedurally unfair.
The court held that while the statutory duty to provide a broad and balanced curriculum lies with schools, teachers are expected to deliver it. Leger’s refusal to teach certain curriculum segments was contrary to the school’s policy.
The court found that the interference with Leger’s rights was prescribed by law and proportionate. The PCP and Secretary of State correctly applied the proportionality test, balancing Leger’s rights with the public interest.
The court concluded that the publication of the decision, including Leger’s name, was lawful and proportionate. It served the legitimate aims of maintaining public confidence in the teaching profession and safeguarding pupils.
The claim for judicial review was dismissed.