This was the conclusion of the Court in the case of Richard Howlett v Health Professions Council (2009).

H’s fitness to practise was found to be impaired by the Health Professions Council’s Competence and Conduct Committee. He was struck off the register. On appeal to the High Court, the judge decided that the committee had failed to give reasons for its decision to strike H from the register. That failure to give reasons was an error of law. All factors should have been expressly addressed by the committee to explain why the ultimate sanction was appropriate.