Dr Sadiq v General Medical Council: High Court upholds erasure for sexual misconduct

Dr Adnan Sadiq v The General Medical Council [2025] EWHC 3062 (Admin) concerned an appeal against erasure from the medical register following findings of sexual misconduct. The High Court dismissed all seven grounds of appeal, upholding both the Medical Practitioners Tribunal's factual determinations and the sanction imposed.

Dr Sadiq, a foundation year doctor, met Ms A through Tinder in November 2020. The Tribunal found he had used his professional status to gain her trust before engaging in non-consensual sexual acts, including digital penetration, applying pressure to her neck, and exposing himself. Whilst Dr Sadiq admitted sending inappropriate WhatsApp messages, he denied the remaining allegations throughout the proceedings.

Procedural challenges and vulnerable witnesses

The appeal raised substantial procedural objections. Dr Sadiq contended that his counsel was prevented from adequately cross-examining Ms A due to repeated interruptions necessitated by her autism diagnosis. Ms Justice Obi DBE rejected this ground, finding that special measures under Rule 36 of the GMC Fitness to Practise Rules 2004 were properly implemented. The Tribunal's interventions during cross-examination were proportionate and targeted, designed to accommodate Ms A's vulnerabilities without prejudicing the defence case. Cross-examination spanned 84 pages of transcript and covered all material aspects of the allegations.

Further procedural complaints—including alleged time constraints on closing submissions and inappropriate questioning—were similarly dismissed. The court found that whilst minor irregularities occurred, including the temporary disconnection of the Legally Qualified Chair's camera and the omission of Dr Sadiq's Reflections document from the Stage 2 bundle, these did not affect the fairness or outcome of proceedings.

Factual findings and credibility assessments

The substantive challenge concerned the Tribunal's acceptance of Ms A's evidence. Dr Sadiq highlighted inconsistencies between her police interview and witness statements, particularly regarding whether she was standing or kneeling during the alleged assault, and her description of a "freeze response" versus active resistance.

Applying principles from Sastry v General Medical Council [2021] EWCA Civ 623 and Byrne v GMC [2021] EWHC 2237 (Admin), the court emphasised that findings of primary fact, particularly those founded on witness credibility, are "virtually unassailable" absent objective grounds for interference. The Tribunal had properly considered the evidence holistically, including contemporaneous messaging and testimony from Ms A's friends regarding early disclosures.

Dr Sadiq's contamination arguments—that Snapchat messages sent by Ms A to friends months after the incident may have influenced their accounts—were rejected. Unlike cases involving multiple complainants where cross-admissibility principles require express consideration of contamination risk, this was a single-complainant case where the friends' evidence provided context rather than independent corroboration.

Sanction and public protection

The court affirmed that erasure was appropriate and proportionate. The Tribunal had applied the Sanctions Guidance correctly, concluding that Dr Sadiq's conduct was fundamentally incompatible with continued registration. The sexual misconduct undermined public trust in the medical profession and could not be adequately addressed through suspension. Whilst Dr Sadiq sought to distinguish his case from comparable matters, each case must be assessed on its own factual matrix.

The appeal proceeds by way of rehearing under CPR 52.21(3), permitting the court to reconsider evidence and reach independent conclusions. However, deference to the Tribunal's evaluative judgements remains context-dependent, with particular weight accorded to specialist understanding of professional standards and credibility assessments based on live evidence.

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