In R (on the application of Puri) v Bradford Teaching Hospital NHS Trust  IRLR 582 HC, the High Court held that rights under art.6 of the European Convention on Human Rights were not engaged in respect of the composition of disciplinary and appeal panels determining disciplinary action against a doctor. In the circumstances of the case, the hearings were not determining the doctor's ability to practise his profession, but merely his ability to remain in a particular post.
The High Court has held that art.6 of the European Convention on Human Rights was not engaged in internal disciplinary proceedings where the employee was not, as a result, deprived of the right to practise his profession.
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