There is a right to legal representation at internal disciplinary hearings under Article 6 of the European Convention on Human Rights

Kulkarni v Milton Keynes Hospital NHS Trust [2009] EWCA Civ 789

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  • The contracts of NHS doctors and dentists have been construed to include a right to have legal representation when accused of misconduct or capability.
  • Where there are serious accusations that could lead to a ban on future work (by a monopoly employer) Article 6 of the European Convention on Human Rights gives the right to legal representation at internal disciplinary hearings (obiter)

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A doctor faced with accusations of serious professional misconduct was not allowed to have a legal representative at his disciplinary hearing. An express contractual term was relied on to refuse this. Legal representation had formerly been allowed and the revoking of this right gave the same disciplinary treatment to doctors and dentists as with other employees. The court accepted however that the result of being dismissed by the NHS that is effectively the sole employer means that dismissal means the end of a career.

The Court of Appeal decided to construe relevant provisions in the contract as allowing Dr Kulkarni to be represented at his disciplinary hearing by a lawyer instructed by his professional body the MPS.

Although the immediate relevance of this case (applying to professional and non-professional conduct) is for NHS doctors and dentists faced with disciplinary action over alleged misconduct or issues of capability it is expected that it will also apply to those employees of public bodies who are threatened by disciplinary action that could affect their careers.

Obiter dicta in the Court of Appeal Judgment referred to Article 6 of the ECHR in holding that those working for employers who are effectively running a monopoly and who face serious charges will mean that they are entitled to expect that any internal disciplinary hearings are compliant with Article 6 (such as legal representation and even the right to have a disciplinary hearing heard before an independent panel).

This case follows on from and confirms the High Court decision in R (on the application of G) v The Governors of X School where a 23 year old music assistant had kissed a 15year old pupil. He was dismissed and reported to the Secretary of State for Children Schools and Families to determine whether he should be entered in the register of those unsuitable to work with children.

The claimant had not been allowed by the school to be represented by his lawyer at the internal disciplinary hearings. In the High Court the judge ruled that in the light of the consequences of dismissal by a school he should have been allowed to be represented by his legal representative at the internal disciplinary hearings.

The High Court found that internal disciplinary and appeal procedures are part of the same procedure as those of the Secretary of State's procedures for entry onto the register of those unsuitable to work with children. This meant that internal disciplinary and appeal procedures must be the same as those of the Secretary of State with regard to registering those unsuitable to work with children. The school was allowed to appeal to the Court of Appeal.


The transcript of this case can be found (usually at the Bailli or Employment Appeals websites)  Here

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