Professional Standards Authority for Health and Social Care; Dr Cian Hughes v General Medical Council & Anor [2026] EWHC 1138 (Admin)
Summary
A High Court appeal by the Professional Standards Authority against a GMC tribunal decision to suspend Dr Cían Hughes for 12 months rather than erase him from the medical register.
The tribunal had found that Dr Hughes, after first meeting Patient A when she was a minor patient in 2011, sent her inappropriate messages outside her medical care, later pursued an improper emotional relationship, then a sexual relationship, and that his actions were sexually motivated.
It also found that he knew Patient A was vulnerable because of her age and mental health.
The tribunal concluded that his conduct amounted to serious misconduct and that his fitness to practise was impaired.
On sanction, however, the tribunal imposed a 12-month suspension rather than erasure, taking account of matters such as his admissions, apology, remediation, insight, CPD, testimonials, lack of other complaints, and the passage of time.
The Professional Standards Authority appealed, arguing essentially that suspension was too lenient and that erasure was the only proper sanction, particularly because Dr Hughes had abused his professional position in relation to a vulnerable patient.
It also argued that the tribunal was wrong to find that Dr Hughes had not exploited Patient A’s vulnerability.
Mr Justice Murray dismissed the appeal.
Sanction was an evaluative, multi-factor decision for a specialist tribunal, and the court should interfere only if the decision was wrong or outside the reasonable range open to it.
This was a difficult and factually nuanced case.
The tribunal had considered the relevant sanctions guidance and was entitled to conclude that, although the case came close to erasure, erasure would be disproportionate.
The court rejected the argument that the tribunal had failed to consider the relevant guidance pointing towards erasure in cases involving vulnerable patients.
The court also rejected the argument that the tribunal was wrong to find no exploitation of Patient A’s vulnerability; it held that, although the misconduct was serious, that particular conclusion was open to the tribunal on the evidence.
The judge accepted that the maximum 12-month suspension was a significant sanction and within the range reasonably available to the tribunal.
The tribunal had found that Dr Hughes, after first meeting Patient A when she was a minor patient in 2011, sent her inappropriate messages outside her medical care, later pursued an improper emotional relationship, then a sexual relationship, and that his actions were sexually motivated.
It also found that he knew Patient A was vulnerable because of her age and mental health.
The tribunal concluded that his conduct amounted to serious misconduct and that his fitness to practise was impaired.
On sanction, however, the tribunal imposed a 12-month suspension rather than erasure, taking account of matters such as his admissions, apology, remediation, insight, CPD, testimonials, lack of other complaints, and the passage of time.
The Professional Standards Authority appealed, arguing essentially that suspension was too lenient and that erasure was the only proper sanction, particularly because Dr Hughes had abused his professional position in relation to a vulnerable patient.
It also argued that the tribunal was wrong to find that Dr Hughes had not exploited Patient A’s vulnerability.
Mr Justice Murray dismissed the appeal.
Sanction was an evaluative, multi-factor decision for a specialist tribunal, and the court should interfere only if the decision was wrong or outside the reasonable range open to it.
This was a difficult and factually nuanced case.
The tribunal had considered the relevant sanctions guidance and was entitled to conclude that, although the case came close to erasure, erasure would be disproportionate.
The court rejected the argument that the tribunal had failed to consider the relevant guidance pointing towards erasure in cases involving vulnerable patients.
The court also rejected the argument that the tribunal was wrong to find no exploitation of Patient A’s vulnerability; it held that, although the misconduct was serious, that particular conclusion was open to the tribunal on the evidence.
The judge accepted that the maximum 12-month suspension was a significant sanction and within the range reasonably available to the tribunal.