Billy Law
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Allegation
As a registered Dietitian (DT24773):
1. On or around 12 January 2018 you advised Service User J to change their medication and/or instructed their GP, in writing, to change Service User J’s medication, when you had:
a. no prescription training;
b. not discussed with or sought authorisation to do so from a senior nurse or consultant.
2. On or around 13 February 2018, in respect of Service User H, you requested a change of prescription from their GP, when you had:
a. no prescription training;
b. not discussed with or sought authorisation to do so from a senior nurse or consultant.
3. On or around 18 January 2019 you recommended an increase to Service User G’s prescribed medication when you had:
a. no prescription training
b. not discussed with or sought authorisation to do so from a senior nurse or consultant.
4. On or around 31 May 2019 you advised Service User I to change their medication and/or on 3 June 2019 instructed their GP, in writing, to change Service User I’s medication, when you had :
a. no prescription training;
b. not discussed with or sought authorisation to do so from a senior nurse or consultant.
5. On or around 12 July 2019 you advised and/or instructed a GP, in writing, to prescribe an additional medication to Service User B when you had:
a. no prescription training
b. not discussed with or sought authorisation to do so from a senior nurse or consultant.
6. On or around 25 July 2019, you provided dosage instructions to Service User A for their new medication which was:
a. not clinically justified.
b. placed Service User A at a risk of harm.
7. On or around 26 July 2019 you advised and/or instructed a GP, in writing, to change Service User A’s medication, specifically insulin for diabetes, when you had:
a. no prescription training;
b. not discussed with or sought authorisation to do so from a senior nurse or consultant.
8. On or around 17 January 2020, in respect of Service User C, you provided advice on medication reduction/s when you had:
a. no prescription training
b. not discussed with our sought authorisation from a consultant or senior nurse
c. been told not to remove medications or ask GP’s to prescribe new medications
d. been told to liaise with a senior nurse or consultant about ideas for changing medication or doses
9. On or around 17 January 2020, you commenced Service User C on a reduced calorie diet when:
a. it was not clinically appropriate
b. you had not undertaken and/or recorded screening for eating disorders
c. you had not arranged medical screening by a physician
d. you had not discussed with or sought authorisation from a senior nurse or consultant
10. On or around 13 January 2021 you commenced Service User D on a Very Low Calorie Diet (VLCD) and
a. You did not:
i. undertake and/or record screening for eating disorders
ii. arrange medical screening by a physician
iii. discuss with or seek authorisation from a senior nurse or consultant
iv. update their GP
b. provided advice on medication reduction/s when you had:
i. no prescription training
ii. not discussed with or sought authorisation from a consultant or senior nurse
iii. been told not to remove medications or ask GP’s to prescribe new medications
iv. been told to liaise with a senior nurse or consultant about ideas for changing medication or doses
11. On or around 14 January 2021, you requested a GP to change Service User F’s medication, specifically rapid insulin, when you had:
a. no prescription training
b. had not discussed with or sought or authorisation from a senior nurse or consultant
c. been told not to remove medications or ask GP’s to prescribe new medications
d. been told to liaise with a senior nurse or consultant about ideas for changing medication or doses
12. On or around 2 February 2021 you
a. commenced Service User E on a Very Low Calorie Diet (VLCD) when:
i. when it was not clinically appropriate
ii. you had not undertaken and/or recorded screening for eating disorders
iii. you had not arranged medical screening by a physician
iv. you had not discussed or sought authorisation from a senior nurse or consultant
b. provided advice on medication reduction/s when you had:
i. no prescription training;
ii. not discussed with or sought authorisation from consultant or senior nurse
iii. been told not to remove medications or ask GP’s to prescribe new medications
iv. been told to liaise with a senior nurse or consultant about ideas for changing medication or doses
13. In respect of particulars 1-12, you worked beyond your scope of practice.
14. The matters set out in particulars 1-13 above amount to misconduct and/or lack of competence.
15. By reason of misconduct and/or lack of competence your fitness to practise is impaired.
Finding
Preliminary Matters
Service
1. The Panel was provided with a copy of the Notice of Hearing sent by email to the Registrant’s registered email address on 22 May 2026, setting out the time, date and venue for this review and the possibility of the Panel proceeding without the Registrant in the event that he did not attend.
2. The Panel was provided with a delivery receipt for the email.
3. The Panel was thus satisfied with service in this case.
Proceeding in the Absence of the Registrant
4. The Registrant did not attend the review hearing. Ms Khorassani, on behalf of the HCPC, made an application to proceed in the Registrant’s absence and outlined the relevant case law and guidance from the HCPTS Practice Note in relation to Proceeding in the Absence of the Registrant.
5. The Panel took into account the submissions made by Ms Khorassani, together with the advice of the Legal Assessor and bore in mind that, although it had discretion to proceed in the absence of the Registrant, this discretion should be exercised with the utmost care and caution.
6. The Panel noted that the HCPC had taken all reasonable steps to notify the Registrant of the hearing, he had been given clear notice of the hearing and also given an opportunity to attend and be heard. They considered the two emails received from the Registrant dated 23 June 2026, both confirming that he would “not be attending the hearing” and that neither email had requested an adjournment of the hearing, raised any objection to the matter proceeding in his absence, or suggest that he would attend on a future date if that matter did not proceed.
7. The Panel noted that this was a mandatory review of the substantive order and the importance to carry out the review before the Order expired on 7 August 2026. The Panel felt there was likely to be a disadvantage for the Registrant in not attending but agreed that he had voluntarily absented himself and had waived his right to attend in light of the emails received. The Panel therefore considered that any disadvantage to the Registrant was outweighed by the need to review the Order in place.
8. The Panel also noted they must have regard to all the circumstances of which it is aware, with fairness to the Registrant being a prime consideration, but balanced with fairness to the HCPC and the public interest.
9. In the circumstances, the Panel decided it was both fair and appropriate to proceed with the review in the absence of the Registrant.
Background
10. The Registrant is a registered Dietitian. He had been employed as a Band 6 Community Diabetes Dietitian at the Diabetes Care for You Service (‘the Service’) between January 2017 and October 2021. The Registrant was not qualified or employed to act as an independent/supplementary prescriber. Such activities lay outside of the scope of his practice and his employment contract with the Service.
11. The Service raised concerns about the Registrant after a service user called the Service to clarify changes to his insulin prescription made by the Registrant. This call prompted the Service to investigate and to conduct a review of the Registrant’s work. The review revealed concerns that the Registrant had:
a. provided incorrect diet advice to service users;
b. improperly suggested very low calorie diets (‘VLCDs’);
c. requested changes to medication beyond the scope of his professional practice; and that
d. this had all continued despite the Registrant being advised not to do this, in person and in writing, following a meeting with his clinical supervisor on 29 August 2019.
12. The service user group seen by the Registrant were vulnerable. They included persons who had Type 1 Diabetes and Type 2 Diabetes. Changes in the provision of insulin medications and dietary changes, including very sudden and substantial reductions in calorie intake daily, could have serious adverse impacts for service users’ health and wellbeing.
13. The interactions of insulin dose, delivery, and frequency and a daily deficit in calories all had the potential to cause the service users to experience unanticipated and unpredictable hyperglycaemic or hypoglycaemic episodes.
14. In circumstances where the service users were operating machinery or were driving or were at risk of falls, the risks to the service users and to other members of the public were high.
15. For these reasons, changes to a service user’s insulin medication or diet regime had to be discussed with team members with expertise in the area, including Nurse prescribers and Consultant Physicians.
Substantive Hearing on 04-10 December 2024
16. The matter eventually came to hearing before the substantive hearing panel on 04-10 December 2024. The Registrant did not attend, service was found proved, and the panel acceded to the HCPC application to proceed in the Registrant’s absence. The HCPC called various witnesses, including the Professional Lead of Diabetes for the Service, the Diabetes Nurse Consultant, and a HCPC-registered Dietitian.
17. The panel found all particulars proved. The panel found misconduct in respect of Particulars 1 to 13, except for Particular 9. Further, it found that the Registrant was impaired in relation to the personal and public components.
18. In relation to sanction, no mitigating factors were identified and various aggravating factors were found. The panel found a breach of service user trust. It noted the repetition of concerns and a pattern of unacceptable behaviour after 3 October 2019, extending over two years and remaining unaddressed by the Registrant at this substantive hearing. There was no evidence of insight, remorse, or apology. The panel also found a lack of meaningful, targeted, and relevant remediation. It concluded that there remained a risk of serious service user harm, although it recognised that there was no evidence of actual harm in this case.
19. In relation to sanction, the substantive hearing panel stated:
“221. The Panel next considered a Suspension Order. The Panel had regard to paragraph 121 of the Sanctions Policy which provides:
“121 A Suspension Order is likely to be appropriate where there are serious concerns which cannot be reasonably addressed by a Conditions of Practice Order, but which do not require the Registrant to be struck off the Register. These types of cases will typically exhibit the following factors:
• the concerns represent a serious breach of the Standards of conduct, performance, and ethics;
• the Registrant has insight;
• the issues are unlikely to be repeated;
• there is evidence to suggest the Registrant is likely to be able to resolve or remedy their failings”.
222. Having taken account of those factors, the Panel considered that a Suspension Order was the appropriate order in this case. In coming to this view, the Panel recognised one factor relevant in the foregoing list is the gateway factor of serious breach of standards of conduct. The Panel had no evidence to suggest that the other factors set out above were engaged. The Panel however recognised that, taking the totality of the information available to it, together, there was scope for a realistic view that a Suspension Order could provide the Registrant with the platform and the time to productively address the Panel’s determination and the concerns set out in it.
223. The Panel was influenced by what was said in relation to the Registrant’s clinical abilities by AO and Dr Blades. The Panel recognised that service users and the public can always be protected from the failings of Dietitians by removing them completely from the Register. The Panel recognised however that this is a sanction of last resort where the Registrant’s conduct was wholly incompatible with continued registration. In this case, there was scope for the view that the Registrant was acting in the best interests of the service users, although his professional arrogance may have blinded him to the clear risks to service users of his decisions which were made outside the scope of his practice and without appropriate discussions with the MDT.
224. The Panel recalled that the High Court set out in the case of Giele v General Medical Council [2005] EWHC 2143 (Admin) that where possible, protective sanctions can, in appropriate cases, fully protect the public by acting in a way that can restore an otherwise safe and effective practitioner to serve the needs of the public. The Registrant was highly regarded professionally despite his failings and the appearance of professional arrogance. The Panel considered that a period of suspension could provide him with the opportunity to engage with the Panel’s findings and to begin the process of reflection and remediation necessary to allow him to return to practise.
225. One of the factors in support of a Suspension Order is the Registrant’s insight. In this case, the Registrant has demonstrated no insight of any meaningful kind, nor has he provided an apology or any expression of remorse. The Panel had already determined that the Registrant’s conduct may be repeated with potential risks for service users and for the reputation of the Dietitian profession. However, given the potential for the Registrant to reverse that lack of engagement and insight during a period of suspension with the consequent potential benefits for the public if successful, the Panel came to the view that public confidence in the profession and regulatory process would not be undermined if a Suspension Order was imposed in this case.
226. The Panel therefore decided to impose a Suspension Order for 12 months.
…
234. The Panel considered that a Panel which later reviewed the Registrant’s suspension would be assisted by;
• The Registrant’s attendance and participation in the review
• Information regarding the Registrant’s current professional or voluntary employment relevant to the profession of Dietitian
• Being provided by the Registrant with a reflective piece of writing which engaged closely with the Panel’s findings in this hearing, and Evidence of targeted professional education courses dealing with
a. The importance of acting always within the scope of practice
b. Timely and relevant discussions with professional colleagues in the interests of service users
c. Address the insight gained by the Registrant in regard to the risks for the public and for service users of his failings”
First review hearing - 20 November 2025
20. At the review hearing the panel considered submissions on behalf of the Registrant and on behalf of the HCPC.
21. In summary, the Registrant provided a reflective statement of three pages to the HCPC in advance of the hearing. The Registrant submitted that he was shocked by the evidence from the initial hearing and needed time to reflect, apologising for not attending that hearing and for the mistakes that put patients at risk. He explained that he had not worked as a Dietitian since leaving the Service and is currently employed as a remote health coach for the National Diabetes Prevention Programme (NDPP), where he seeks support appropriately and refers clinical queries to relevant professionals. In responding to the allegations, he attributed his behaviour to a combination of personal and emotional pressures. He described steps he had taken to improve his emotional awareness and resilience. He accepted that he had sought external validation, had not prioritised professional standards, and should have sought more support. He stated that he had since revisited key professional standards and guidance, understood the need to work within his competence, and had maintained non-practising British Dietetic Association (‘BDA’) membership.
22. In his oral evidence, the Registrant accepted the allegations in full and reiterated his unreserved apology, acknowledging that he had acted outside his scope of practice and created risks for service users. He confirmed that he should have referred matters to senior colleagues or appropriate specialists rather than making any suggestions himself. He further explained the steps he had since taken in relation to personal and emotional pressures. He accepted that his record-keeping had fallen below standard and stated that he now understands the importance of seeking timely support, consulting colleagues, and adhering strictly to professional boundaries.
23. While he confirmed he had not yet completed targeted professional courses, he noted that the courses he had undertaken related to his current role, such as health and safety and conflict resolution, and that he remained willing to undertake any further training required. He also outlined his continued work as a remote health coach within defined limits, his intention to return to Dietetic practice gradually with appropriate supervision, stating that he would need to ease himself back into practice, increase his clinical knowledge, and welcome supervision and additional support. He expressed willingness to work under conditions if required and invited the panel to permit his return to practice, with or without conditions. He stated that, if faced with similar circumstances in the future, he would slow down his reactions, recognise early signs of stress, and reach out to colleagues for timely support.
24. On behalf of the HCPC, Ms Sampson submitted that the Registrant had not fully addressed all the serious concerns identified at the substantive hearing, noting that the matters involved vulnerable service users. She acknowledged his engagement, attendance, and the progress reflected in his statement and oral evidence but submitted that his insight remained limited. In her view, he focused primarily on his personal circumstances and found it difficult to articulate the impact of his actions on service users or how he would manage similar situations differently in future. She also submitted that he had produced no evidence of targeted professional education or structured remediation and that, given the burden on him to demonstrate steps taken, a risk of repetition remained. On this basis, she submitted that he remained impaired on both the personal and public components.
25. In respect of the appropriate sanction, Ms Sampson invited the panel to replace the suspension with conditions of practice for a period of 6–12 months, which would enable him to return to work safely while completing the necessary remediation, such conditions to include weekly managerial supervision and completion of the targeted professional development recommended by the panel who considered the substantive matter in December 2024. She submitted that this approach would be proportionate, offer adequate public protection, and support the Registrant’s safe return to practice.
26. The panel noted the following matters:
i. The Registrant’s misconduct involved a sustained pattern of working outside scope of practice, inadequate record-keeping, and failures that placed vulnerable service users at risk.
ii. The panel found that the Registrant’s insight remained limited and not yet sufficiently developed as he provided very little reflection on the potential harm to service users, the impact on colleagues, or the wider consequences for public trust in the profession, noting that he had been given several opportunities to reflect on these issues but had not done so meaningfully.
iii. The Registrant had expressed remorse and apologised but it was not persuaded that this demonstrated a fully formed or reliable insight demonstrating the depth of understanding regarding risk, duty of care, or professional accountability required of a safe autonomous practitioner.
iv. The remediation evidence provided by the Registrant fell considerably short due to:
• The absence of any evidence of relevant Continuing Professional Development (‘CPD’) and he had undertaken only generic mandatory training associated with his current non-Dietetic role;
• The absence of steps to maintain or update his Dietetic knowledge;
• The lack of targeted CPD the previous panel had identified;
• Not seeking advice from professional bodies, colleagues, or the HCPC about suitable courses.
27. The panel also noted the limited evidence regarding his current employment and the lack of testimonials, references, or evidence of working effectively within scope or within professional frameworks, despite the previous panel clearly indicating that such evidence would be helpful. The panel stated that the absence of this evidence raised concerns about personal accountability and reduced the panel’s confidence that the Registrant currently possessed the safeguards necessary to prevent repetition.
28. In respect of impairment, the panel concluded as follows:
“For those reasons, the Panel concluded that the Registrant has not yet developed sufficient insight, has not remedied the concerns, and presents a genuine risk of repetition. The Panel therefore found that his fitness to practise remains impaired on the personal component. The Panel also found the public component of impairment to be engaged. Members of the public would expect a Dietitian to maintain up-to-date professional knowledge, practise safely within scope, and demonstrate clear understanding of the risks to service users. The Registrant had not demonstrated awareness of how his previous conduct undermined confidence in the profession. His limited insight and lack of structured remediation mean that public confidence in the profession and the regulatory process would be undermined if he were permitted to return to unrestricted practice.”
29. In respect of sanction, the panel concluded as follows:
“The Panel first considered taking no further action. Given the ongoing risks identified and the absence of sufficient remediation, this would not provide any protection to the public and would be inappropriate.
The Panel next considered a Conditions of Practice Order. However, the Panel concluded that workable or effective conditions could not be formulated at this stage. The level of supervision and oversight required to mitigate risk would, in effect, require constant monitoring. The Registrant’s insight remains only partial, he has undertaken no dietetic CPD for four years, he has no evidence of current competence, and he produced no references or testimonials demonstrating adherence to professional expectations. His proposals for practice were vague, reactive, and largely suggested by others during questioning. The Panel determined that conditions could not adequately protect the public at this time.
The Panel then considered a Suspension Order. The Panel noted the Registrant’s attendance, his engagement at this review, and that he has taken steps to address some personal issues. The Panel considered that a further period of suspension would provide him with a further opportunity to undertake the structured remediation, targeted CPD, and reflective work required to demonstrate safe and competent future practice. A longer period would be disproportionate given some developing insight, but a short, focused period was necessary to allow meaningful progress before the next review.
The Panel therefore determined that a 3-month Suspension Order is the appropriate and proportionate sanction. This period is sufficient to allow the Registrant to take active steps to remediate the concerns and to gather appropriate evidence without removing him from the profession for longer than necessary.”
30. The panel also stated that a review panel may be assisted by the following information:
“• The Registrant’s attendance and participation in the review;
• A reflective piece (for example using Gibbs’ Reflective Cycle) addressing:
• the impact on service users, colleagues, and public confidence.
• evidence of how the Registrant will manage future personal stressors to avoid repetition;
• Evidence of up-to-date Dietetic CPD and relevant professional development.
• Targeted CPD in working within scope, multidisciplinary working, and professional accountability. Should the Registrant find verifiable CPD on the matter of scope practice difficult to achieve, then a future panel may instead be assisted by a reflective written piece on what the Registrant understands on this matter having read relevant documentation; and
• Testimonials or references from his current employer addressing his ability to work within frameworks, boundaries, and policies;”
Second review hearing – 26 March 2026
31. At the second review hearing the panel considered submissions on behalf of the Registrant and on behalf of the HCPC.
32. The Registrant provided numerous reflective pieces for the panel to consider, including evidence of CPD and testimonial evidence. In his oral evidence he drew the panel’s attention to a number of matters, including:
i. His continued shame and deep regret regarding the behaviour which is the subject of the substantive allegations and findings;
ii. His awareness of the risks to patients resulting from his past conduct, including coma or death resulting from failures in dietetic management;
iii. His awareness of the loss of trust and confidence in the dietetic profession as a result of his past actions and risk of the reputation of the profession being tarnished, as well as the effect on his colleagues.
iv. His awareness of and reflection on the events and willingness to access support, which includes a number of layers of support;
v. The evidence from his current supervisor demonstrating his ability to work in a professional manner within a scope of practice and his ability to work in an accountable and consistently professional way, including asking for support from senior colleagues.
vi. Evidence of ongoing CPD with examples of updated knowledge on diabetes prevention programmes.
vii. His attendance at the BDA classroom course and reflective piece;
viii. In his role as a health coach on the National Diabetes Prevention Programme (NDPP), he works on a platform where he is able to ask for support from colleagues and feels he has a strong support network, including regular supervision reviews every 3 months;
ix. He feels ready to return to practice and he would do this by firstly undertaking shadowing with a local diabetes team to help identify his current knowledge gaps.
33. The Registrant confirmed that he would welcome the opportunity to return to practice as a Dietitian and would comply with any conditions of practice which might be directed by the Panel.
34. On behalf of the HCPC, Ms Sampson submitted that the question for this panel in reviewing the Order was whether the position had materially changed. She confirmed that the HCPC made no submissions as to whether the Registrant’s fitness to practice remained impaired, maintaining a neutral position, leaving that determination as a matter for the panel.
35. Ms Sampson helpfully took the panel through the recommendations made by the previous panel and highlighted some of the evidence the Registrant provided in response, which could be summarised as follows:
i. The Registrant’s attendance at the hearing was noted;
ii. A reflective piece addressing the impact on service users, colleagues, and public confidence, together with evidence of how the Registrant will manage future personal stressors to avoid repetition:
• the Registrant had provided several reflective pieces, including on “Managing Future Personal Stressors to Avoid Repetition” and the “Impact on Service Users, Colleagues and Public Service Reflective Practice”, in which the Registrant addressed the concerns previously identified and outlined the repercussions of his behaviour, as well as providing a plan for the future.
• The Registrant also relied on a reflective evaluation following attendance at the BDA CPD course on “Introduction to Professional Practice and Dietetic Workforce”, in which he addressed the importance of delivering safe and effective dietetic care, including working within scope of practice, professional accountability, and multidisciplinary working.
iii. Evidence of up-to-date Dietetic CPD and relevant professional development and targeted CPD in working within scope, multidisciplinary working, and professional accountability, or a reflective written piece:
• The Registrant had submitted certificates for several courses, undertaken both before and since the previous review, including some targeted CPD.
• The Registrant had included reflections alongside his BDA course certificates.
iv. Testimonials or references from his current employer addressing his ability to work within frameworks, boundaries, and policies:
• The Registrant provided a single testimonial from his current supervisor.
36. In assessing current impairment, the panel considered both the personal and public components.
37. In relation to the personal component the panel noted the following matters:
i. The Registrant’s misconduct involved a sustained pattern of working outside scope of practice, inadequate record-keeping, and failures that placed vulnerable service users at risk.
ii. The material provided by the Registrant evidenced some steps he had taken in the period since the last review which the panel commended.
iii. The Registrant had some insight but this was still developing. The Registrant did, in his written and oral evidence, address the potential harm to service users, the impact on colleagues, and the wider consequences for public trust in the profession.
iv. Whilst the Registrant had again apologised for his behaviour and explained the context at the time, the panel was not satisfied that he had articulated a clear understanding of the importance of practicing within his scope of practice which is required of a safe autonomous practitioner.
v. The Panel noted the Registrant had positively engaged with CPD and provided evidence of this, including a number of reflections, the Panel noted that this was not targeted CPD relating to the issues of concern. Specifically, the Panel would expect to see evidence of CPD directly related to practicing as a Dietitian working within his scope of practice and for the Registrant to clearly show his understanding in relation to professional standards.
vi. The Registrant had not practised as a Dietitian for over four years and the position remains that he had undertaken limited training to respond to the previous review panel’s concerns, whilst successfully completing the required mandatory training associated with his current non-dietetic role. He had taken limited steps to update his Dietetic knowledge and had undertaken only some of the targeted CPD the previous panel had identified. The panel noted some written inaccuracies in the clinical CPD evidence submitted and encouraged proof reading of submissions for a future panel e.g. CPD in terms of Type 2 Diabetes risk and stated age ranges at heightened risk.
vii. The panel noted the positive testimonial from his current supervisor, which indicated his ability to work within frameworks relating to his current role. The panel noted he was, in his oral evidence today, beginning to develop his understanding of ways in which he could take further steps towards updating his knowledge and skills through professional conversations with colleagues who are practicing Dietitians.
viii. The panel concluded that although showing some progression since the last review, the Registrant did not yet show he fully understands the aspects of his practice that need to change and he was not yet able to demonstrate how he would confidently work within HCPC standards and ensure the safety of patients.
ix. For these reasons, the panel concluded that the Registrant has not yet developed a sufficient level of insight, and has not remediated the concerns. He has not demonstrated that he has taken sufficient steps to mitigate against future repetition of the failings and a real risk of harm to members of the public remains. The Panel therefore found that his fitness to practise remains impaired on the personal component.
38. In relation to the public component of impairment the panel noted the following:
i. Members of the public would expect a Dietitian to maintain up-to-date professional knowledge, practise safely within their scope of practice, and demonstrate clear understanding of the risks to service users.
ii. The Registrant had not yet demonstrated a sufficient and fully developed awareness of how his previous conduct undermined confidence in the profession.
iii. His developing insight and lack of targeted remediation mean that public confidence in the profession and the regulatory process would be undermined if he were permitted to return to unrestricted practice.
39. The Panel therefore found that the Registrant’s fitness to practise to be impaired on both the personal and public components.
40. In respect of sanction the panel concluded as follows:
“The Panel first considered taking no further action. Given the ongoing risks identified and the absence of sufficient remediation, this would not provide any protection to the public and would be inappropriate.
The Panel next considered whether a Conditions of Practice Order was appropriate and proportionate. The Panel carefully considered the circumstances where a condition of practice order is appropriate and considered each of the requirements as set out at paragraph 153 of the HCPC Sanctions Policy dated 2 March 2026. The Panel also considered the circumstances as set out in paragraphs 154 – 156 of that Policy, and following due consideration agreed that at this stage an order of conditions is not appropriate. The panel has found that the Registrant is engaging with the fitness to practice process, the misconduct found proven was not in the higher level of the more serious examples in paragraph 155. However, the panel reminded itself that the Registrants’ conduct was not minor and it took place repeatedly, even after he was spoken to by a senior colleague. For these reasons the panel found the Registrant has not been able to show that a combination of conditions can be found that will be workable and sufficiently protect the public.
The Panel was satisfied that in these circumstances today, a condition of practice order would not mitigate the ongoing risks identified to ensure the safety of patients. The level of supervision required currently remains so high that the Panel was concerned it would act as a suspension.
The Panel decided that a further period of suspension will allow for the Registrant to have a fuller engagement with targeted CPD relating directly to the issues of working within his scope of practice. The Panel concluded that this will sufficiently protect the public until the Registrant can show he fully understands the aspects of his practice which need to change and for him to demonstrate to a panel how he would confidently work within the HCPC standards and ensure the safety of patients.
The Panel concluded that a short period of a further four months would provide an opportunity to the Registrant to demonstrate full insight and the remediation required for safe and competent future practice. A longer period would be disproportionate given that the Panel has found the Registrant is developing his understanding and has shown he is taking positive steps towards remediation. The Panel considered that this period of time will allow the Registrant to continue to take more focused steps to fully remediate the failings.
The Panel cannot tie a future panel but considered that a review panel may be assisted by the following:
• The Registrant’s attendance and participation in the review;
• Evidence of up-to-date Dietetic CPD targeted at a minimum level of Band 5 level competencies and relevant professional development; and
• Should the Registrant find verifiable CPD difficult to achieve, then a future panel may be assisted by written accounts of professional discussions with Dietetic colleagues and reflections on professional journal articles about working within a Registered Dietitian’s scope of practice in the area of Diabetes.
Given the Registrant has now been out of dietetic practice as a Registered Dietitian for more than 2 years, then a period of return to practice activity per HCPC guidelines will be required before any future return to independent practice.”
Submissions
41. On behalf of the HCPC, Ms Khorassani confirmed that this was a mandatory review of a substantive order in accordance with Article 30(1) of the Health and Professions Order 2001. She confirmed the Order was due to expire on 7 August 2026 and invited the Panel to extend the existing Suspension Order for a period of 6 months.
42. Ms Khorassani referred to the background of the Order, confirming that this was a third review and the purpose was to consider if the Registrant’s fitness to practice is currently impaired.
43. Ms Khorassani referred the Panel to the case of Abrahaem v GMC [2008] EWHC 183 (Admin) which confirmed that the Panel’s task “is to consider whether all the concerns raised in the original finding of impairment...[have] been sufficiently addressed”. She confirmed that there is a ‘persuasive burden’ on the Registrant to demonstrate that he has fully acknowledged the deficiencies which led to the original finding and has addressed that impairment sufficiently “through insight, application, education, supervision or other achievement...”. She submitted, however, that since the last review, the Registrant had not engaged with the HCPC process in a manner that may assist the Panel in their decision, therefore there was no evidence to suggest his fitness to practice is no longer impaired.
44. Ms Khorassani submitted that the Panel should consider what, if anything, has changed since the current Order was imposed and referred the Panel to the factors to be taken into account which include:
• the steps which the Registrant has taken to address any specific failings or other issues identified in the previous decision;
• the degree of insight shown and whether this has changed;
• the steps which the Registrant has taken to maintain or improve his professional knowledge and skills; and
• whether any other fitness to practise issues have arisen.
Ms Khorassani confirmed that, in relation to the last factor, no other fitness to practice issues have arisen in relation to the Registrant.
45. Ms Khorassani also referred the Panel to Dame Janet Smith’s comments within her Fifth Report for the Shipman Inquiry and the four-part legal test for determining impairment in fitness to practise hearings, which had been adopted into leading UK case law, in particular CHRE v Nursing and Midwifery Council and Grant [2011] EWHC 927 (Admin). The four limbs of this test require tribunals to determine whether the practitioner’s fitness to practise is impaired in the sense that the practitioner:
a) has in the past acted and/or is liable in the future to act so as to put a patient or patients at unwarranted risk of harm;
b) has in the past brought and/or is liable in the future to bring the medical profession into disrepute;
c) has in the past breached and/or is liable in the future to breach one of the fundamental tenets of the medical profession; and/or
d) has in the past acted dishonestly and/or is liable to act dishonestly in the future.
46. Ms Khorassani confirmed that, whilst a panel cannot tie a future panel, the panel at the last review made recommendations to the Registrant that would assist the Panel at this review. She submitted that the Registrant had not provided any evidence or documentation to assist the Panel in making their decision today as he had not engaged with the HCPC since that last review.
47. Ms Khorassani detailed the personal and public components of impairment that the Panel must consider and submitted that all HCPC registrants must comply with the standards of conduct, performance and ethics, referring to relevant standards that applied in this case. She also referred to the Panel’s overarching duty to protect the public.
48. Ms Khorassani submitted that, should the Panel find the Registrant’s fitness to practice is not currently impaired then it was open to it to allow the Order to expire on 7 August 2026.
49. However, should the Panel find that his fitness to practice is currently impaired, Ms Khorassani submitted it should proceed to consider the appropriate sanction, confirming the Panel may extend or further extend the Order, replace the Order or make an order that could have been made by the initial panel at the Final Hearing. She referred the Panel to the Sanctions Policy and confirmed that any sanction should be considered in ascending severity.
50. Ms Khorassani submitted that the HCPC’s position was that the Registrant’s fitness to practise remains impaired and invited the Panel to further extend the Suspension Order for a period of 6 months to allow him to re-engage with the HCPC process and comply with the Order.
Legal Assessor’s Advice
51. The Legal Assessor advised that this is a Review under Article 30(1) of the Health Professions Order 2001, and the Panel should consider the HCPTS Practice Notes on Review of Article 30 Sanction Orders and Fitness to Practise Impairment as well as the Sanctions Policy. The Panel was reminded that Article 30(1) of the Health Professions Order 2001 provides Panels with a power to:
- extend the period for which the order has effect;
- make an order which could have been made when the order being reviewed was made.
52. The Panel was reminded that the review process is not a mechanism for appealing against or ‘going behind’ the original finding that the Registrant’s fitness to practice is impaired. The purpose of the review is to consider:-
• Whether the Registrant’s fitness to practise remains impaired; and
• If so, whether the existing order or another order needs to be in place to protect the public.
53. The Legal Assessor advised that one of the key issues to be addressed is what, if anything, has changed since the current order was imposed and confirmed the factors to be taken into account include, as detailed by Ms Khorassani on behalf of the HCPC.
54. The Panel was advised that their task “is to consider whether all the concerns raised in the original finding of impairment...[have] been sufficiently addressed”. Abrahaem v GMC [2008] EWHC 183 (Admin). There is a ‘persuasive burden’ on the Registrant to demonstrate at a review hearing that he has fully acknowledged the deficiencies which led to the original finding and has addressed that impairment sufficiently “through insight, application, education, supervision or other achievement...”.
55. The decision reached must be proportionate, striking a fair balance between interfering with the Registrant’s ability to practise and the overarching objective of public protection.
56. The Panel was reminded of the HCPC’s overarching objective which is the protection of the public and the purpose of fitness to practise proceedings is not to punish registrants for their past acts and omissions, but to protect the public from those who are not fit to practise. It does this by:
• protecting, promoting and maintaining the health, safety and well-being of the public;
• promoting and maintaining public confidence in the professions it regulates;
• promoting and maintaining proper professional standards and conduct for members of those professions.
57. In determining fitness to practise allegations, panels must take account of two broad components: the ‘personal’ component: the current competence and behaviour of the registrant concerned; and the ‘public’ component: those critically important public policy issues.
58. The Panel was advised that, in making proportionate decisions on sanction, panels need to strike a balance between the competing interests of the registrant and the HCPC’s overriding objective to protect the public. Therefore, decisions should deal with the concerns raised, but be fair, just and reasonable. Sanctions are not intended to be punitive. Panels should only take the minimum action necessary to ensure the public is protected. This means considering the least restrictive sanction available to them first and only moving on to a more restrictive sanction if it is necessary to protect the public.
Decision
Impairment
59. In reaching its decision the Panel considered the submissions of the parties and all relevant information before it. It accepted the Legal Assessor’s advice and referred to the relevant HCPTS Practice Notes.
60. The Panel first considered whether the Registrant’s fitness to practise remains impaired. The Panel was aware that the persuasive burden is upon the Registrant to demonstrate that his fitness to practise is no longer impaired. The Panel had regard to the decisions of the substantive panel and the review panels. However, it comprehensively reviewed the matter and exercised its own judgment in reaching its decision.
61. The Panel first considered whether the Registrant’s fitness to practise is currently impaired looking at both the personal component and the public component.
62. In relation to the personal component the Panel considered what had changed since the last hearing. The Panel was disappointed to note that the Registrant had failed to engage with the HCPC since the last hearing, having considered his positive engagement with the first and second reviews and the progress he had made. The Panel had received no information from the Registrant to explain why he had disengaged and simply had the comment within his email to the HCPC on 23 June 2026 confirming he had “no documents to submit”. The Panel accepted it was not appropriate to speculate why the Registrant had failed to engage with the process, given his previous motivation, but agreed it would have been useful for him to include some reasons within his email as to why he was unable to attend or comply with the recommendations from the previous review.
63. The Panel therefore agreed there was no evidence to suggest or confirm that anything had changed since the last hearing. It was noted by the panel at the last hearing that, whilst the Registrant had made some progress, the panel still found that his fitness to practise was impaired. The panel had provided detailed recommendations to the Registrant at the last hearing in relation to what would assist a future panel but there was no evidence or documentation to suggest they had been acted upon and certainly the first recommendation of engagement had not been acted upon according to the HCPC and also evidenced by the Registrant’s failure to attend the review today. The Panel there had no evidence that the Registrant was actively addressing the issues raised or concerns of the previous panels and there was nothing to persuade the Panel that he was working towards the standards required of a dietitian.
64. The Panel considered to what extent the original panel’s concerns had been addressed and it was noted that the persuasive burden was on the Registrant. The Panel considered the detailed and focused recommendations given to the Registrant at previous reviews which would address the concerns of the original panel. Whilst the Panel acknowledged the significant progress made by the Registrant since the Suspension Order was initially imposed over 18 months ago, there was still insufficient evidence to address the original panel’s concerns. At the last review, there were still concerns that, whilst he had significantly progressed on his journey in addressing the issues raised, he still was unable to persuade the panel that he was aware why his practise was wrong and, until he was able to do that, then the original concerns were still there. The Panel agreed the concerns were very serious, including prescribing outside the scope of his practise, which he continued even after being clearly told not to and also advising patients to follow low calorie diets without communicating with the relevant specialists or the multi-disciplinary team. The Panel considered the potential serious consequences of these actions and the risk to the public as a result.
65. The Panel considered the case of Abrahaem v GMC [2008] EWHC 183 (Admin) as referred to by Ms Khorassani and the Legal Assessor noting the task “is to consider whether all the concerns raised in the original finding of impairment...[have] been sufficiently addressed”. The Panel agreed the Registrant had not persuaded them that he has fully acknowledged the deficiencies which led to the original finding and has addressed that impairment sufficiently “through insight, application, education, supervision or other achievement...”.
66. The Panel agreed that without the evidence set out above there continues to be a risk of repetition and therefore a real risk of harm. The Panel therefore determined that the Registrant’s fitness to practice remained impaired on the personal component.
67. The Panel went on to consider the public component. It agreed that the allegations proved were serious and that the Registrant had not demonstrated a sufficient level of insight. The Panel acknowledged his insight was developing, that he had appeared remorseful at a previous review and appreciated the impact of his actions on stakeholders. However the Panel agreed there was still a risk of repetition as the serious concerns raised had not been fully addressed. As a result, the Panel agreed there inevitably remains a risk to the public and there is a need to protect the public from risk of harm.
68. In considering the public component the Panel considered that the Suspension Order had been in place for 18 months and was being reviewed on a regular basis and had been extended twice already. The Panel agreed that this should sufficiently mark the public interest concern that any member of the public would have in relation to standards and confidence in the profession and the regulator.
69. The Panel found that the Registrant’s fitness to practise was impaired on the public component in relation to the protection of the public.
70. The Panel accordingly concluded that the Registrant’s fitness to practise is currently impaired on both the personal and the public component.
Sanction
71. The Panel looked at the Sanctions Policy considering the least restrictive sanction available to them first and only moving on to a more restrictive sanction if it is necessary to protect the public. The Panel was aware that the sanction is not a punishment for the Registrant but that it may have a punitive effect. The Panel was aware that once they reached a tentative view that an appropriate sanction has been identified, two further considerations should be made. One is to consider the next more severe sanction to the one identified in order to ensure that it sufficiently addresses the aims of a sanction. The other is to be satisfied that it is proportionate in the sense that it is no more severe than is required.
72. The Panel first considered mediation, taking no action or a caution order and determined that these were not appropriate due to the serious nature of the concerns and the risk of repetition identified. None of these options would place any actual restriction on the Registrant’s practice, and therefore would not address the ongoing risks that the Panel has identified and would not adequately protect the public. In addition, these outcomes would not satisfy public confidence in the profession or the regulatory process.
73. The Panel considered if any appropriate conditions of practice could be formulated to address the concerns and protect the public. The Panel agreed that, had the Registrant engaged with the process since the last review, then it may have been possible to formulate some appropriate conditions. However, without his attendance or engagement, the Panel could not be satisfied the Registrant would abide by any conditions even if they could be formulated. The Panel considered the Registrant’s failure to work in partnership with others and the requirement for a high level of supervision, in light of the repeated behaviour, even after a warning had been given. The Panel considered that until this element of the misconduct has been remediated that no workable or enforceable conditions could be formulated in the circumstances to address the risks concerned and to protect the public
74. The Panel therefore went onto consider the HCPC’s application to extend the current Suspension Order for a minimum of 6 months. It referred to the HCPC’s Sanction Policy which states:
A suspension order is likely to be appropriate where there are serious concerns which cannot be reasonably addressed by a conditions of practice order, but which do not require the registrant to be struck off the Register. These types of cases will typically exhibit the following factors:
• the concerns represent a serious breach of the Standards of conduct,
performance and ethics;
• the registrant has insight;
• the issues are unlikely to be repeated; and
• there is evidence to suggest the registrant is likely to be able to resolve or
remedy their failings.
75. The Panel agreed the current Suspension Order remained necessary as there was no evidence to suggest it should move away from that, in light of the Registrant’s lack of engagement since the last review. The Panel considered how long a Suspension Order can continue as it had been in place for over 18 months already, however, it agreed that the Order remained the safest approach to protect the public. The Panel agreed that an extension to the Order of 6 months would allow the Registrant a chance to finally complete the recommendations made at the last review and prove he was capable of being remediated, allow him to remedy his failings and prove he was able to address the concerns raised. The Panel therefore determined that the Suspension Order was proportionate and necessary to protect the public.
76. The Panel considered a Striking Off Order and agreed this was not proportionate in light of the significant progress made by the Registrant, although now for some reason he had regressed since the last review. The Panel agreed the Registrant should be allowed a further 6 months to persuade a future panel that he was no longer impaired by responding to the recommendations given. The Panel agreed that a Striking Off Order was disproportionate in the circumstances, given the previous history of engagement and agreed it was fair to allow the Registrant the opportunity to re-engage and prove the concerns have been remediated and addressed as required.
77. The Panel took into account the effect an extension to the Suspension Order would have on the Registrant, but concluded that public protection outweighed the Registrant’s interests.
78. The Panel therefore determined that the Suspension Order made on 10 December 2024 and extended on 20 November 2025 and 26 March 2026 should be extended for a further 6 months.
79. The Panel acknowledged that it cannot tie a future panel but considered that a review panel may be assisted by the following:
• The Registrant’s attendance and participation in the review;
• Evidence of relevant up-to-date Dietetic CPD targeted at a minimum level expected of a HCPC registered Dietitian (equivalent to NHS/AFC Band 5); and
• Should the Registrant find verifiable CPD difficult to achieve, then a future panel may be assisted by written accounts of professional discussions with Dietetic colleagues and reflections on professional journal articles about working within a Registered Dietitian’s scope of practice in the area of Diabetes.
Order
ORDER: The Registrar is directed to suspend the registration of Mr Billy Law for a further period of 6 months on the expiry of the existing Order.
Notes
The Order imposed today will apply from 7 August 2026. This Order will be reviewed again before its expiry on 7 February 2027.
Hearing History
History of Hearings for Billy Law
| Date | Panel | Hearing type | Outcomes / Status |
|---|---|---|---|
| 29/06/2026 | Conduct and Competence Committee | Review Hearing | Suspended |
| 26/03/2026 | Conduct and Competence Committee | Review Hearing | Suspended |
| 20/11/2025 | Conduct and Competence Committee | Review Hearing | Suspended |
| 04/12/2024 | Conduct and Competence Committee | Final Hearing | Suspended |