Hough v Health and Care Professions Tribunal Service: striking-off upheld after paramedic misconduct findings

The Administrative Court has dismissed an appeal by a registered paramedic against findings of misconduct, impairment and a striking-off order made by a Panel of the Health and Care Professions Council's Conduct and Competence Committee. The judgement, handed down by Mrs Justice Hill on 27 March 2026, addressed all four grounds of appeal and confirmed the Panel's decision in full.

Karl Hough, an Advanced Paramedic with approximately 30 years' experience at North West Ambulance Service NHS Trust, faced charges arising from two separate incidents: the treatment of a child with a rare neurological condition in March 2018 and the treatment of an adult cardiac arrest patient in July 2020. The Panel found proved charges including inappropriate administration of morphine and midazolam, failure to maintain adequate records and — most significantly — dishonesty, in that Hough had recorded himself as having administered midazolam when it had in fact been administered by a junior colleague who lacked the authority to do so under the relevant Patient Group Direction.

Facts and findings

On the first ground, the appellant argued the Panel had failed to address inconsistencies in the HCPC's witnesses' evidence and that its reasons were inadequate. Mrs Justice Hill rejected both arguments. The Panel had carefully considered the reliability of each witness, noting their consistency with contemporaneous accounts and the absence of any tendency to exaggerate. By contrast, the Panel found the appellant himself to be an unconvincing witness, citing his habit of deflecting questions, attributing improper motives to others, and giving oral evidence that was in material respects inconsistent with his own earlier accounts. Applying the deference thresholds established in Byrne v General Medical Council [2021] and Evboren v Nursing and Midwifery Council [2024], the court found no exceptional circumstances warranting interference with the findings of fact.

The misconduct challenge fared no better. Arguments that there were no relevant policies in place governing delegation of drug administration, and that Hough had lacked adequate training in completing patient report forms, were each rejected. The Panel had accepted clear evidence that Hough had received training on Patient Group Directions and, as an Advanced Paramedic operating at Masters level, could not credibly claim ignorance of record-keeping requirements. The dishonesty finding was upheld on the basis that Hough had known delegation was impermissible and had falsified the record to conceal it.

Impairment and sanction

On impairment, the appellant contended that four years of unblemished practice under interim conditions demonstrated no ongoing risk. The Panel acknowledged this, noting it did not doubt Hough's general capability. The critical issue, however, was whether he could be relied upon consistently to practise within professional standards. The Panel concluded he could not, identifying a common "attitudinal shortcoming" underlying both incidents and finding that, even at the conclusion of a lengthy hearing, Hough still lacked genuine insight into the gravity of his conduct. Citing Sayer v General Osteopathic Council [2021], Mrs Justice Hill confirmed this was a matter pre-eminently for the Panel, which had heard the appellant give evidence on two separate occasions and was well-placed to assess his demeanour and attitude.

The sanction ground drew on comparisons with Bawa-Garba and Abrahaem, but the court declined to extract general principles from those fact-specific decisions. The Panel's conclusion that suspension would serve no purpose — because the risks at the end of any suspension period would remain unchanged — was characterised as an unimpeachable application of the HCPC's Sanctions Policy. The combination of dishonesty, failure to work in partnership, two separate incidents, and incomplete insight brought the case squarely within the criteria for a striking-off order.

The appeal was dismissed and the appellant ordered to pay costs summarily assessed at £7,017.60, with six months allowed for payment.

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