An employee may be entitled to have a lawyer at a disciplinary hearing where the outcome of the hearing could deprive him of any future in that profession.

The Court of Appeal has applied its own obiter comments in Kulkarni and ruled that an employee is entitled to legal representation at a disciplinary hearing where the outcome could be to deprive him of the right to practice his profession (rather than just losing one specific job).

It is particularly relevant to employers in the education and caring sectors, financial services and other regulated professions. (G v X and Y, CA).