Okpara v Nursing and Midwifery Council [2016] EWHC 1058 (Admin)

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This decision confirms a NMC review panel's ability to impose a new and more severe sanction at its discretion. Further, where allegations of dishonesty have previously been found proven, a review panel is able to impose a striking off order, irrespective of whether or not a registrant has been suspended for two years prior.

A striking off order does not interfere with a registrant's Article 8 rights and although Article 1, Protocol 1 may be engaged, proportionality is a recognised criterion by which to judge a sanction whether or not the convention rights are engaged.