Hanna Grzelczak v General Dental Council [2026] EWHC 890 (Admin)

reg feed

The High Court allowed Ms Hanna Grzelczak’s appeal against the GDC tribunal’s sanction of erasure and substituted a 6-month suspension, subject to a review hearing.

Ms Grzelczak, a dentist qualified in Poland and later registered in the UK, had admitted sending four emails in 2023 containing racially motivated comments about “Indian” dentistry and Damira Dental Studios. The tribunal had found misconduct, impairment, and imposed erasure with immediate suspension.

The court held that, although the misconduct was serious and represented a serious departure from professional standards, erasure was excessive and disproportionate. In particular, the judge found:

the conduct was repeated, but only across four emails over about four weeks;
Ms Grzelczak’s insight was limited, but not so persistently lacking as to justify erasure;
There was some evidence of remediation, including admissions, reflective work, CPD, and completion of the PASS scheme;
The tribunal had not adequately explained its finding of shortcomings in remediation;
The risk of repetition was reduced by the passage of time, her remediation efforts, and the deterrent effect of suspension;
The tribunal had identified only a general risk of harm, not serious harm or a continuing risk of serious harm of the level contemplated for erasure.

The judge emphasised that the purpose of fitness to practise proceedings is public protection, not punishment, and that under section 29 of the Dentists Act 1984 the court was conducting a rehearing rather than a narrow review.

The substituted sanction was a 6-month suspension from the date of the appeal decision, with a review hearing at the end. At that review, Ms Grzelczak is expected to provide further CPD, reflective learning, and an updated reflection statement addressing discrimination, respectful communication, professional behaviour, insight, impact on public confidence, and how repetition will be avoided.

Bookmark

Please login to bookmark