R (Glawdys Leger) v Secretary of State for Education [2025] EWHC 665 (Admin)

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.

Purdy v DPP [2010] 1 AC 345
Sutcliffe v Secretary of State for Education [2024] EWHC 1878
R (on the application of Ngole) V University of Sheffield [2019] EWCA Civ 1127
Lee v Ashers Baking Co Ltd [2018] UKSC 49; [2020] AC 413
Handyside v UK [1976] ECHR 5
R (European Roma Rights Centre) v Immigration Officer at Prague Airport [2004] UKHL 55
ex parte Westminster City Council [1985] ICR 827
Bayatyan v Armenia [2012] 54 EHRR 15
Miller v College of Policing [2020] EWHC 225 (Admin)
Wallace v Secretary of State for Education [2017] EWHC 109
Bank Mellat v HM Treasury (No. 1) [2013] UKSC 38