This article highlights the 11 February 2022 decision in Health Care Complaints Commission V Godwin [2022] NSWCATOD 17, in which a general practitioner, Dr Godwin was reprimanded and his registration suspended for 6 months by the NSW Civil & Administrative Tribunal (‘Tribunal’) in February 2022.

The practitioner in the matter of Hampshire v Health Care Complaints Commission [2021] NSWCA 283 was first registered as a medical practitioner in 1976, and had been a consultant psychiatrist since 1988.

His registration was cancelled by the NSW Civil and Administrative Tribunal in 2020 because he had sent sexually inappropriate text messages to a young woman after a medico-legal assessment of her in April 2017. He had also failed to comply with health conditions on his registration that imposed limits on his intake of alcohol and sedatives, and he was considered not competent to practice due to alcohol dependence.

This matter is not the first to clearly illustrate the importance of complying with professional standards, and the risks of failing to do so.  Hampshire v Health Care Complaints Commission [2021] NSWCA 283 is similar to the matter of Rahman v Health Care Complaints Commission [2021] NSWCA 247 (discussed in Holman Webb’s December 2021 article), in that the practitioners in question both had histories of non-compliance with conditions, which gave the respective Tribunal Members no confidence that either would adhere to further conditions imposed.