Dr Seshni Moodliar v General Medical Council [2025] EWHC 913 (Admin)

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Dr. Moodliar challenged the tribunal’s decision on fourteen grounds, which were grouped into seven principal areas of challenge, including the admission of prejudicial material, the tribunal’s refusal to recuse itself, the tribunal’s approach to evidence and standard of proof, reliance on hearsay evidence, inadequate reasons for findings, the sanction of erasure, and the tribunal’s application of the dishonesty test.

Dr. Moodliar’s appeal also included an application for an extension of time to file the appeal, which was granted due to misleading advice from the Medical Practitioners Tribunal Service regarding the appeal deadline.

The background of the case reveals that Dr. Moodliar had been involved in previous tribunal proceedings in 2022, where she was found to have acted dishonestly in her role as an expert witness. Further allegations of misconduct arose from her work as a defence expert witness in a 2019 criminal trial, leading to the tribunal’s decision to erase her from the register.

The legal framework for the regulation of doctors emphasises public protection, with the General Medical Council’s overarching objective being the protection of the public, maintaining public confidence in the medical profession, and upholding professional standards.

The judgment addressed each of Dr. Moodliar’s grounds of appeal, ultimately dismissing the appeal but extending the time for filing it. The court found that the tribunal had not improperly considered prejudicial material, had not demonstrated apparent bias, had properly approached the evidence and standard of proof, and had given adequate reasons for its findings. The tribunal’s decision to erase Dr. Moodliar from the register was deemed appropriate given the seriousness of her misconduct and lack of insight.

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