Healthcare professionals who practise overseas should be aware that regulatory problems abroad do not necessarily stay abroad.

The recent High Court decision in General Medical Council v Grajn [2026] EWHC 1157 (Admin) is a stark reminder that overseas disciplinary findings and sanctions can have serious consequences for a professional’s registration in the UK.

What happened?

The doctor was found guilty of professional misconduct in Australia following findings that he had entered into an inappropriate personal and sexual relationship with a patient or former patient following transplant treatment. The Australian regulator imposed a two-year disqualification from applying for registration.

The GMC subsequently brought proceedings in the UK. It was also alleged that the doctor failed to disclose the Australian findings and sanction to both the GMC and his NHS employer.

The Medical Practitioners Tribunal found the allegations proved and imposed a sanction. However, the GMC considered the outcome insufficient and appealed to the High Court.

The High Court’s decision

The High Court agreed with the GMC and quashed the tribunal’s decision.

The Court held that the tribunal had failed properly to address the seriousness of the Australian misconduct findings when assessing impairment and sanction. The case was remitted to a fresh tribunal for reconsideration.

Importantly, the judgment reinforces two key principles.

Failure to disclose can become a regulatory issue in its own right

Healthcare regulators expect openness and candour from registrants.

The allegations against the doctor included failing to disclose the Australian findings to both the GMC and his employer. The case serves as a reminder that failing to report overseas regulatory action may itself give rise to fitness to practise concerns, regardless of the underlying conduct.

Overseas findings are relevant to UK fitness to practise

Many professionals mistakenly believe that disciplinary findings made abroad are solely a matter for the foreign regulator.

The High Court made clear that this is not the case. Overseas findings can be highly relevant when UK regulators assess a practitioner’s current fitness to practise, particularly where issues of professional boundaries, integrity, patient safety or public confidence are involved.

In short, professional misconduct does not become irrelevant simply because it occurred in another country.

A warning for all regulated professionals

Although this case involved a doctor and the GMC, the same principles apply across the healthcare sector, including professionals regulated by the NMC, HCPC, GDC, GPhC and Social Work England.

Most regulators require registrants to disclose overseas disciplinary findings, sanctions, restrictions and, in some circumstances, ongoing investigations. Failure to do so can itself become a fitness to practise issue.

If you become the subject of regulatory proceedings abroad, it is essential to understand your disclosure obligations and the potential impact on your UK registration.

Seek specialist advice early

Questions about whether, when and how to disclose overseas regulatory issues are often complex. Taking advice before responding to a regulator or employer can be critical.

Kings View Chambers has a proven track record representing doctors and other healthcare professionals in fitness to practise proceedings, including cases involving overseas disciplinary findings and cross-border regulatory issues.

Rated Excellent and recognised for its expertise in professional discipline and healthcare regulation, Kings View Chambers regularly assists professionals facing serious regulatory investigations and proceedings.