This case should be of interest to professional bodies, particularly those concerned with the discipline of professional colleagues.

The disciplinary panels of bodies which regulate professional conduct conventionally have power to suspend a professional's right to practise for a specified period. They do so by directing that the entry of his (or her) name on the professional register be suspended for the specified period. Usually that power is accompanied by a power (but occasionally by a duty) of a panel to conduct a later review of the suspension in order to determine whether to direct its continuation beyond the specified period or to make some other direction. This appeal concerns the ambit of the inquiry which, in the case of one of these disciplinary panels, should be undertaken in the course of a review.

In 2002 Mr Khan was registered as a pharmacist. He practised in Glasgow. In 2012 the General Pharmaceutical Council ("the council"), by its registrar, referred to its Fitness to Practise Committee ("the committee") an allegation that his fitness to practise as a pharmacist was impaired by reason of criminal convictions for domestic violence which had been recorded against him. On 27 June 2013 the committee found that the impairment of his fitness to practise was established. When it turned to identify the sanction which would properly reflect the gravity of the misconduct for which he had been convicted, the committee rejected the more common option of suspending his right to practise. Instead it directed that his entry in the register of pharmacists be altogether removed.

The claimant won his appeal to the Court of Session and the council appealed to the UK Supreme Court. Mr Khan cross-appealed. The council's appeal concerned whether a review committee may impose a further suspension to reflect the original committee’s conclusion that the gravity of the registrant’s misconduct demanded a longer period of suspension than the 12 months it was permitted to imposed. Mr Khan cross-appealed against the Extra Division’s implicit rejection of his argument that in any event his removal from the register was disproportionate. The UKSC allowed both the appeal and the cross-appeal.

The main reason for the more common suspension is to allow for a period of rehabilitation, which is reviewed at the end of the year. Does the damage to the reputation of the profession continue at the end of that year? In the case of Mr Khan, the court was reluctant to interfere in the decisions of a professional body of experts but concluded that the penalty imposed was disproportionate to the offence and the original committee itself had acknowledged that its direction for removal might appear harsh.
http://www.bailii.org/uk/cases/UKSC/2016/64.html

As ever, you can see the UKSC's summary judgement being delivered on YouTube:
https://www.youtube.com/watch?v=TarKwjgW4V4