Mrs Paula J May

Preliminary matters

Service

1.The Notice of Hearing was sent to the Registrant, by email, to her registered email address on 27 April 2023 informing her that there would be a substantive hearing starting on 5 June 2023 via video hearing. A Certificate of Service has been provided.

2. The Panel was satisfied that service had been effected in accordance with the Procedure Rules and Practice Note on Service of Documents.

Proceeding in absence

3. Mr Smart on behalf of the HCPC applied for the hearing to proceed in the Registrant’s absence. He submitted that the Registrant had voluntarily absented herself and that no application had been made for an adjournment. He submitted that it would be fair and in the interests of justice to proceed in the Registrant’s absence.

4. The Panel had regard to the HCPTS Practice Note on “Proceeding in the Absence of the Registrant” and accepted the advice of the Legal Assessor. The Panel was mindful that this was a substantive hearing with witnesses in attendance ready to give evidence. The Panel noted that the Registrant had responded to the notice of hearing by email dated 23 May 2023 advising that she would not be in attendance and written submissions were provided. No request for an adjournment has been made.

5. The Panel considered that the Registrant had voluntarily absented herself, that an adjournment would be unlikely to secure the Registrant’s attendance at a future date and that no useful purpose would be served by an adjournment. The Panel was mindful of the need to proceed expeditiously where it is appropriate to do so. In all the circumstances the Panel decided that it was fair and in the interests of justice to proceed with the hearing in the absence of the Registrant.

Application for anonymity

6. Mr Smart advised that reference may be made inadvertently to Service User 1’s name and asked that this be redacted from the transcript and any decision anonymised to protect his privacy.

7. The Panel was mindful of the ‘open justice’ principle and considered the Procedure Rules and agreed to redact the names of the witnesses as matters relating to the health of Service User 1 may be raised.

Background

8. The Registrant is a Podiatrist working in private practice. On 23 November 2020, the HCPC received a referral dated 22 October 2020 from the complainant, Service User 1. In the referral, Service User 1 alleged that the Registrant overcharged him for what he believed were ‘bespoke’ orthotics. Service User 1 stated that the insoles were marketed to him as custom made and bespoke by the Registrant.

9. Service User 1 alleges he was told by the Registrant that he would need two sets of insoles. The first pair would be a soft insole and then 18 months later he would progress to hard insoles. To create both insoles, Service User 1 alleged that the Registrant measured his feet using a ruler and protractor from the back of his heel. He stated that no Plaster of Paris mould or digital scan were taken of his feet. The soft insoles were provided in the spring of 2018.

10. Service User 1 received the hard insoles in or around 25 February 2020 and these were allegedly described by the Registrant as having been made using new NASA technology. Service User 1 stated that he wore the new, hard insoles for a few months, but that they insoles started to separate. Service User 1 informed the Registrant who advised that she would replace the insoles free of charge.

11. The replacement insoles provided did not fit the Service User 1’s shoe and were nearly an inch smaller. On 9 July 2020, Service User 1’s wife contacted the Registrant to discuss her concerns with the insoles to which the Registrant responded that the manufacturer must have used the wrong mould. Service User 1’s wife advised that no mould had been taken of Service User 1’s foot and then proceeded to request a full refund. The Registrant provided a full refund on 16 July 2020.

12. On 24 July 2020, the Service User 1 met another Podiatrist, PS and they discussed the insoles provided by the Registrant. PS expressed concerns around the cost of the insoles. The Registrant showed PS the old pair of soft insoles that the Registrant had previously given him for which he paid around £300. PS investigated the orthotics further and found the exact insoles online for £29.34. PS prepared a letter for the complainant to include in his subsequent referral to the HCPC.

13. The HCPC’s case is that the terms ‘bespoke’ and ‘custom-made’ should be interpreted using their ordinary meaning, namely ‘made to fit a specific customer’. The HCPC contends that the service user was entitled to and, indeed, led to believe by the Registrant that the insoles had been uniquely manufactured using the measurements taken at his appointment, rather than, for example, cut to size by the Registrant.

Evidence

14. The Panel heard live evidence from PS, Service User 1 and Person A (Service User 1’s wife). Their accounts were unchallenged by the Registrant during the course of the hearing due to her absence.

15. PS gave evidence of his understanding of the three types of orthotics available and informed the Panel that he had inspected the first pair of orthotics supplied by the Registrant to Service User 1 in the spring of 2018. He stated that he did not consider the orthotics to be ‘bespoke’ and he had formed this opinion based on his education in Podiatry to degree level and his experience post qualification. He further based this on the fact that the insoles had no modifications or customisations and due to their shape and material used. He described them as an ‘off the shelf / prefabricated Interpod soft/ medium orthotic made for an over pronated foot’.

16. PS stated that he considered a bespoke orthotic to be a product designed or manufactured for that individual which would normally be produced by taking a cast or a 3D scan of the foot and sending that to the manufacturer. He went on to state that the terms used can be confusing as different manufacturers use different terms.

17. PS explained that ‘off the shelf’ orthotics can be ‘semi-customised’ to an extent by adding or removing parts. He had calculated, based on his own purchase of a similar orthotic supplied by the Registrant to Service User 1, that there had been a 1111% mark up in what the Registrant had charged him. He explained that he would expect a bespoke insole to be made and fitted for that fee.

18. The Panel heard evidence from Service User 1 and Person A regarding their interactions with the Registrant and the conversations which they had around the need for Service User 1 to wear orthotics provided to him by the Registrant.

19. Service User 1 stated that prior to seeing the Registrant he had used basic insoles purchased on the High Street at a cost of between £3 and £8. He visited the Registrant after a recommendation and was assessed by her. Service User 1 states that the Registrant advised him that she could not resolve the problem but was able to help and improve his gait through use of bespoke insoles and improved footwear. Service User 1stated that he was happy to pay the £300 as he thought that it would be a ‘miracle cure’. He stated that the Registrant told him that bespoke insoles and the technology used were unique.

20. Service User 1 explained that his understanding of the word ‘bespoke’ was that the insole had been made specifically for him and for the problems he was having and that the measurements and dimensions were specific to his foot. He stated that no mould or scan were taken of his foot and that the measurements were taken using a ruler and protractor. He was unable to confirm if this may have been a goniometer which was described to him as being L shaped with a hinge and number markings. Service User 1 confirmed that no heat moulding took place. Service User 1 stated that he had read the leaflet given to him by the Registrant at the time which referred to ‘custom made orthotics’.

21. Service User 1 stated that he followed the advice of the Registrant by wearing the soft insoles for a period of 18 months. He returned to get ‘fitted’ for hard insoles after this period as he had been told by the Registrant that he would receive a 50% discount on the cost. When Service User 1 queried the cost and the discount previously referred to, the Registrant told Service User 1 that the discount would only apply if he had purchased the second pair of orthotics within six months. Service User 1 paid the full amount of £350 as he ‘believed that they would continue to do me good’.

22. Service User 1 stated that he did not receive a copy of his medical notes from the Registrant, nor did he receive any receipts or a copy of the refund voucher. When asked about the refund being £315 rather then £350, he stated this may be due to the fact that he had received an anti-fungal cream at the same time.

23. Service User 1 was clear in his view that nothing had been added to the first orthotic supplied to him by the Registrant such as padding or wedges. He was less clear regarding the second orthotic stating ‘I’m pretty sure they didn’t, there may have been something on the ball of the insole’.

24. Service User 1 was clear in his account that the Registrant used the word ‘bespoke’ on a number of occasions and stated that he was present when Person A spoke to the Registrant on the telephone to complain about the insoles and asked for a refund.

25. Person A stated that she had been present when Service User 1 saw the Registrant and confirmed that Service User 1 was advised that bespoke insoles would relieve the pain. She confirmed that the Registrant had stood behind Service User 1 in taking measurements and could not say that a goniometer was not used when it was described to her.

26. Person A described the first pair of orthotics as being white on the bottom, orange on the top and were padded on the arch. She stated that there was no additional padding and both surfaces were smooth.

27. Person A described the issues with the second pair of orthotics splitting and advised that she had spoken with the Registrant on the phone to request a refund and this was agreed to and processed quite quickly. She did not recall the words ‘without prejudice’ or ‘full and final settlement’ being used.

28. In her written submissions, the Registrant denied that she had ever used ‘bespoke’. She stated “When making an orthotic for a patient, I start with a mouldable orthotic which is first heat moulded to the patient’s foot form and then, depending on my diagnosis, I adapt the orthotic by adding podiatric extrinsic postings, padding, reshaping, or making cut-outs. In that respect, I consider the custom fit orthotic has become an item for that individual’s condition and needs of the service user was custom fit and adapted for his individual needs and as a result helped relieve his long-standing chronic foot pain and as he admits provided a good result in relieving his foot pain and found the orthotics comfortable to wear. I absolutely refute the suggestion that I was deliberately trying to mislead Service User 1 or that there was any intention to be dishonest.”

29. The Panel heard submissions from Mr Smart on behalf of the HCPC, considered the representations made by the Registrant and received advice from the Legal Assessor.

Decision on Facts

30. The Panel was aware that the standard of proof in deciding whether the facts are proved is ‘on the balance of probabilities. In other words, the Panel must be satisfied that the act or omission alleged is more likely than not to have occurred before it can find it proved.

31. The Panel considered sequentially:

⦁ whether the facts set out in the allegation are proved;
⦁ whether those facts amount to the ‘statutory ground’ alleged - misconduct.
⦁ In particular the Panel looked at:-

-whether the Registrant misrepresented the orthotics sold to Service User 1 by describing them as bespoke and/or custom-made;
- If so, was the Registrant’s conduct dishonest.

32. The Panel ensured fairness in the proceedings so far as they were able to by taking into account the written representations made by the Registrant. However, the Panel considered that by absenting herself the Registrant’s account was not given on oath, was untested and that she had deprived the HCPC and the Panel of the opportunity to ask her questions to challenge that account.

33. In reaching its decision the Panel has focused on the facts in issue for which the HCPC are required to prove the allegation. The Panel makes no findings of fact in relation to the dates the treatment was provided by the Registrant to Service User 1 or whether the refund was for £350 or £315. The Panel did not have sight of the insoles.

Particular 1 is found proved.

34. The Panel was aware that PS was not giving evidence as an expert witness and that his evidence referenced factual matters and some opinion evidence based upon his specialist expertise as a qualified podiatrist. The Panel was advised by the Legal Assessor that it may attach the weight it sees fit to that evidence in all of the circumstances of the case. The Panel was referred to the case of Multiplex Constructions (UK) Ltd v Cleveland Bridge Ltd. [2008] EWHC 2220 (TCC), where the court allowed an engineer giving factual evidence to also provide statements of opinion reasonably related to facts within his knowledge and relevant comments based on his own experience.

35. The Panel accepted the clear evidence from both Service User 1 and Person A that the Registrant had repeatedly used the word ‘bespoke’ in her appointments with them and concluded that by providing a leaflet to Service User 1 which referred to ‘custom made’ rather than customised orthotics that the Registrant gave Service User 1 the impression that what was being provided was a product specific to his needs.

36. The Panel accepted the evidence from Service User 1 and Person A regarding the use of the word ‘bespoke’ by the Registrant and accepted that Person A had spoken on the telephone with the Registrant. These are issues which the Registrant denies.

37. The Panel was satisfied from the evidence given by PS that the product he examined was ‘off the shelf’ and was not a made to measure product. The Panel concluded from all of the evidence that a ‘bespoke’ product would be something where a cast or scan of the patient’s foot had been taken and that anything else would be an off the shelf product which may be adapted to a service user’s needs.

38. The Panel was of the view that the accounts given by the Registrant were not credible and were inconsistent. In her written representations she denies using the word ‘bespoke’. However, in the email the Registrant sent to the HCPC dated 17 May 2021 and found within the bundle at D36 she states ‘An orthotic is prescribed which is adapted to that person's needs and, in my opinion, this makes it bespoke. However, reflecting on this ambiguity of words in describing orthotics I shall no longer refer to 'bespoke'.’

39. The Panel found on the balance of probabilities that all of the orthotics supplied to Service User 1 were misrepresented as ‘bespoke and / or custom made’ by the Registrant. They reached this conclusion due to the repeated use of the word ‘bespoke’ by the Registrant (evidenced by Service User 1 and Person A), evidence from PS that the first pair of insoles were ‘off the shelf’ with no adaptations, the size of the third pair which were provided in packaging marked ‘S’ and the costs of the insoles provided with no explanation of the cost from the Registrant.

Particular 2 is found proved.

40. The Panel was aware that when making decisions involving alleged dishonesty, it needs to determine whether the Registrant acted as an honest person would have acted in the circumstances. It considered the following:

(1) What did the Registrant know or believe as to the facts and circumstances in which the alleged dishonesty arose?
(2) ) Given the Registrant’s knowledge and belief of the circumstances they were in, was the Registrant’s conduct dishonest by the standards of an “ordinary decent person”?

41. The Panel asked itself whether, taking account of the Registrant’s understanding of the circumstances, an ordinary decent person would find the conduct to be dishonest, which is purely an objective test. The Registrant’s own standards of honesty are irrelevant; they are held to the standards of society in general.

42. The Panel accepted the evidence of Service User 1 that he was sold something different to what he expected in line with what he was charged. The Registrant has failed to address the cost charged and how this was calculated in her representations. The Panel concluded that the costs of the insoles re-emphasised the fact that the product being sold was a bespoke product due to the excessive mark up on the product. The mark up on the product goes beyond what is reasonable (PS said that up to 50% would be reasonable, whereas he had calculated the mark up to be 1111%). Due to this the Panel found that the Registrant has been dishonest in her dealings with Service User 1.

43. The Panel looked at what the Registrant told Service User 1 he was getting against what he was actually provided with and can only conclude that she acted dishonestly.

44. The Panel was referred to the case of Donkin v Law Society [2007] EWHC 414 Admin where the Divisional Court (Maurice Kay LJ and Goldring J) held that, where a professional was accused of acting dishonestly, the panel should have taken account of testimonials about his previous good character and dealt with them in their reasons.

45. The Panel attached limited weight to the references provided by the Registrant in determining the issue of dishonesty. Whilst they confirm the Registrant’s professionalism and clinical practice they do not address the issue of her honesty and integrity. In addition, none of the referees state whether they were aware of the nature of the allegation against the Registrant in these proceedings.

Decision on Grounds

46. The Panel next went on to consider whether or not the facts found proved amounted to misconduct.

47. The Panel heard submissions from Mr Smart and considered the remarks made by the Registrant.

48. The Panel determined that the facts found proved did amount to misconduct on the Registrant’s part. The Panel was referred to Roylance v General Medical Council (No 2) [2000] 1 A.C. 311 where the Privy Council defined “misconduct” as “a word of general effect, involving some act or omission which falls short of what would be proper in the circumstances. The standard of propriety may often be found by reference to the rules and standards ordinarily required to be followed by a medical practitioner in the particular circumstances”.

49. The Panel noted that the dishonesty was not a one-off isolated incident in relation to the Registrant’s dealings with Service User 1.

50. The Panel is of the view that the allegations found proved are serious in nature and fall short of what would be expected in relation to the Standards of Conduct. Performance and Ethics 2016. The Panel considered that the Registrant was in breach of Standards 1, 2.3 and 9.1. In addition, she breached Standards 2.1, 2.3 and 2.4 of the Standards of Proficiency of Chiropodists/Podiatrists.

Decision on Impairment

51. The Panel next went on to consider impairment. It heard submissions from Mr Smart who said the Panel had heard nothing from the Registrant and could not therefore find that she had any insight into her dishonesty and misconduct.

52. The HCPC argues that the conduct is capable of being remedied but there has, to date, been a failure to sufficiently address that misconduct, such that there is an on-going risk of repetition. It is also noted the Registrant does not accept any wrongdoing. For this reason, the HCPC argues that the Registrant’s fitness to practise is currently impaired. The HCPC also argues that the conduct in the allegation is so serious that finding that the Registrant’s fitness to practise is not impaired would undermine both public confidence in the profession and in the regulatory process.

53. The Panel received legal advice from the Legal Assessor and considered fitness to practise with reference to the personal component and the public component. The Panel also took into account the numerous character references provided by the Registrant.

54. The Panel was aware that the test of impairment is expressed in the present tense and the Panel is tasked with determining whether the Registrant’s current fitness to practise is impaired.

55. The Panel attached limited weight to the character references provided by the Registrant as they do not deal with the issue of the Registrant’s honesty and integrity and may have been made in ignorance of the allegation.

56. In considering the personal component, the Panel was persuaded by the arguments advanced on behalf of the HCPC. The Panel had found dishonesty which may be remediable. However, at this time there is no evidence of insight or remediation on the part of the Registrant and there is therefore a risk of repetition. In her written representations the Registrant did not accept that her behaviour fell below the standards required, and she has not demonstrated how and why the misconduct occurred. The Registrant gave a refund in respect of the hard insoles, but that was the extent of her remediation. The misconduct was repeated, and there is nothing before this Panel to suggest that the Registrant has addressed her dishonest behaviour so that it will not be repeated in the future. 

57. The Panel took account of the representations made by the Registrant and while she challenges the evidence of the witnesses in an attempt to undermine them, she has not demonstrated any substantive insight into the behaviour which led to the allegation or been able to account for the significant mark up on the insoles provided to Service User 1, both of which demonstrate lack of insight.

58. The Panel is also under a duty to protect service users from harm and risk of harm and finds that, due to the lack of insight and remediation, there is a risk of the Registrant causing similar harm to service users, some of whom may be financially vulnerable. The public is entitled to expect registrants to be professionally competent and act with decency, honesty and integrity.

59. In considering the public component the Panel concluded that the public would be dismayed if there was no finding of impairment following a dishonesty allegation being found proved. To conclude that the Registrant was not impaired would be akin to endorsing the behaviour. The Panel agrees with the HCPC that the public interest demands a finding of impairment. On any view a finding of dishonesty which was repeated is serious and would cause concern to the public if there was no finding of impairment.

60. The regulatory process is in place to ensure professional standards are maintained and to ensure the public has confidence in the profession and its regulation. The Panel had found that the Registrant was in breach of standards 1, 2.3 and 9.1 of the Standards of Conduct. Performance and Ethics 2016 and Standards 2.1, 2.3 and 2.4 of the Standards of Proficiency of Chiropodists/Podiatrists. These are fundamental tenets of the profession and such breaches bring the profession into disrepute.

61. The Panel therefore finds that the Registrant’s fitness to practise is currently impaired on both the personal and public components.

Decision on Sanction

62. The Panel heard submissions from Mr Smart in respect of sanction. Mr Smart submitted that the Panel must have regard to the HCPC Sanctions Policy. He submitted that the aggravating factors include lack of insight, remorse or apology and referred the Panel to the fact that the Registrant had failed to demonstrate any recognition of Service User 1’s position. Mr Smart highlighted the financial harm caused to Service User 1 which he submits is present in spite of the financial remediation offered by the Registrant by way of partial refund.

63. The Panel received advice from the Legal Assessor. The Panel considered the HCPC Sanctions Policy document. The Panel started by considering the least restrictive sanction first, working upwards only where necessary. The Panel was aware that the final sanction should be proportionate and will be the minimum action required to protect the public.

64. The Panel reminded itself of the principle of proportionality balancing the Registrant’s interests again the public interest. The Panel had in mind the purpose of sanctions is not to punish but to protect the public from harm and to maintain public confidence in the profession and its regulator. The Panel recognised that sanctions can be punitive in character and effect.

65. The Panel referred itself to paragraphs 56-58 of the Sanctions Policy in considering dishonesty and reminded itself of the factors that panels should take into account in this regard which include:

• whether the relevant behaviour took the form of a single act, or occurred on multiple occasions;
• the duration of any dishonesty;
• whether the registrant took a passive or active role in it;
• any early admission of dishonesty on the registrant’s behalf; and
• any other relevant mitigating factors

66. The Panel found dishonesty. The Panel noted that the Registrant had not engaged by attending the hearing and had not provided evidence of insight or remediation into her practice.

67. The Panel looked at the aggravating and mitigating factors present. It considered the aggravating features to be:-

a) The lack of insight, remediation, remorse or apology;
b) The dishonesty was repeated;
c) The dishonesty took place within the workplace;
d) Breach of trust;
e) Financial harm caused to Service User 1.

The mitigating feature is the refund issued to Service User 1 for the hard insoles.

68. The Panel did not think that the matter could be concluded with either no order or a caution. They did not consider these to be appropriate sanctions due to the serious nature of the concerns raised, in particular, the dishonesty was not isolated, there is a risk of repetition and due to the lack of insight or remediation by the Registrant.

69. The Panel finds that while the concerns found proved are capable of remediation a conditions of practice would not be workable in this case because the Registrant had not engaged with the regulatory process and there was no evidence that she had insight into her failings or had taken any action to remediate them. The Panel considered paragraph 107 of the Sanctions Policy which states ‘Conditions will only be effective in cases where the registrant is genuinely committed to resolving the concerns raised and the panel is confident they will do so. Therefore, conditions of practice are unlikely to be suitable in cases in which the registrant has failed to engage with the fitness to practise process or where there are serious or persistent failings’.

70. Further, paragraph 108 states ‘Conditions are also less likely to be appropriate in more serious cases, for example those involving: • dishonesty …’.

71. The Panel concluded that it would not be able to formulate workable conditions which would address the issue of dishonesty as the Registrant was not present and is not engaging with the regulatory process.

72. The Panel concluded that a suspension order is the only sanction which can be imposed in the circumstances. The issues of misrepresentation and overcharging in professional practice is serious.

73. The order is both necessary and proportionate to protect the public from the risk of financial harm that the Registrant poses and to meet the public interest in maintaining confidence both in the profession and the HCPC.

74. The Panel considered paragraph 124 of the Sanctions Policy which states ‘Short-term suspensions can also be appropriate in cases where there is no ongoing risk of harm, but where further action is required in order to maintain public confidence in our professions’. The Panel decided that the proportionate term of the suspension order should be for a period of 6 months.

75. The order will allow the Registrant time to reflect on her behaviours and provide her with an opportunity to remediate and engage in the regulatory process to ensure that there is no risk of repetition.

76. The Panel did consider a strike off order but decided that this would be disproportionate when a suspension order would be sufficient to protect the public and mark the public interest in this case. Strike off orders should be reserved for the most serious cases of misconduct.

77. The Panel considered that a future panel reviewing this order may be assisted by:

a) The Registrant attending the review hearing;
b) The Registrant creating an up-to-date information sheet to be provided to service users which gives unambiguous information regarding assessment for, prescribing and provision of orthotics;
c) A practice position on charging for devices; and
d) A reflective piece on the Panel’s findings and any measures taken to ensure that the misconduct will not be repeated.

Order: The Registrar is directed to suspend the registration of Mrs Paula J May for a period of 6 months from the date this Order comes into effect.

Interim Order

Application

1.Mr Smart submitted that the Panel should consider covering the appeal period by imposing an 18-month Interim Suspension Order on the Registrant’s registration. He submitted that such an order is necessary to protect the public and is otherwise in the public interest and that such an order was appropriate and proportionate in the circumstances of the case.

Decision

2. The Panel heard and accepted the advice of the Legal Assessor.

3. The Panel noted that the Registrant had been informed by the Notice of Hearing dated 27 April 2023 that if this Panel found the case against her to be well founded and imposed a sanction which removes, suspends or restricts her right to practise, the HCPC may make an application to the Panel to impose an interim order to cover any appeal period. The Notice of Hearing clearly stated that, “An interim order suspends or restricts a registrant’s right to practise with immediate effect.” For the reasons set out in its earlier decision to commence the hearing in the absence of the Registrant, the Panel determined that it would also be fair and in the interests of justice to consider an Interim Order application in the Registrant’s absence.

4. The Panel paid careful regard to the HCPTS Practice Note on Interim Orders, which offers guidance on interim orders imposed at final hearings after a sanction has been imposed. The guidance states that registrants should be made aware of the potential for an interim order to be imposed on their registration after the panel has made a substantive order and should be given an opportunity to make representations in respect of an interim order.

5. The Panel recognised that its power to impose an interim order is discretionary and that the imposition of such an order is not an automatic outcome of fitness to practise proceedings in which a Suspension Order has been imposed. The Panel must take into consideration the impact of such an order on the Registrant. However, the Panel was mindful of its findings in relation to the Registrant’s dishonesty and misconduct and the risk of repetition if the Registrant were able to practise without restriction.

6. The Panel decided to impose an Interim Suspension Order under Article 31(2) of the Health Professions Order 2001. The Panel was satisfied that an Interim Suspension Order is necessary for the protection of the public and is otherwise in the public interest to maintain confidence in this regulatory process.

7. The period of this Order is for 18 months to allow for the possibility of an appeal to be made and determined.

Interim Suspension Order:

The Panel makes an Interim Suspension Order under Article 31(2) of the Health Professions Order 2001, the same being necessary to protect members of the public and being otherwise in the public interest.

This order will expire: (if no appeal is made against the Panel’s decision and Order) upon the expiry of the period during which such an appeal could be made; (if an appeal is made against the Panel’s decision and Order) the final determination of that appeal, subject to a maximum period of 18 months.

History of Hearings for Mrs Paula J May