Lanford v General Medical Council

(1989) 1 Med LR 94

PRIVY COUNCIL

Lord BRIDGE of Harwich, Lord BRANDON of Oakbrook, and Lord LOWRY

Medical practitioner — Professional conduct — Disciplinary proceedings — Probative value of evidence before Professional Conduct Committee of General Medical Council — Similar facts rule Charge of serious professional misconduct against general practitioner based on two separate complaints alleging obscene language and improper behaviour — Complainants” evidence strikingly similar with regard to language but not behaviour — Professional Conduct Committee advised by legal assessor that evidence of each complainant was capable of amounting to corroboration of the other's account — Onus and standard of proof — Whether legal adviser had misdirected committee — Whether complaints should have been heard separately — Whether incidents should each have been made the subject of a separate charge of professional misconduct