Bamgbelu v General Dental Council

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In order to demonstrate that deficits identified in a registrant’s practice have been rectified, a registrant must ensure that where conditions have been set by a regulatory body, all measures have been taken to complete these.

A dentist had been subject to a supervision condition following the Professional Conduct Committee of the General Dental Council finding that he had provided inadequate clinical treatment and was guilty of dishonest, misleading and unprofessional conduct.  His registration was subject to 15 conditions for 12 months and included that he should work under supervision.

A review hearing found that he had not followed all of the conditions imposed and had practised for a period without a supervisor. There was therefore limited evidence of his practice due to the lack of supervision. It was decided to extend the supervision condition for a further 9 months.

The dentist appealed against the decision. It was held by the Court that there was a burden on the dentist to demonstrate that he had addressed the Committee’s concerns. Whilst the dentist had complied with 13 of the 15 conditions imposed, it was clear that one of the conditions was that he should have placed himself under supervision. The consequences of his failure were that evidence of his practice could not be considered by the Committee in order to satisfy them that he had addressed their concerns. His complaint was not upheld.