UK: anonymous hearsay evidence will usually be inadmissible in professional disciplinary proceedings

The High Court of England and Wales has held that in general it would be unfair to admit "potentially significant" anonymous hearsay evidence in professional disciplinary proceedings, although there may be exceptions to this in some circumstances. 

Admitting anonymous hearsay evidence is in general unfair because it prevents defendants from challenging evidence by (i) advancing reasons why the witness might have an axe to grind against them or (ii) making enquiries or adducing conflicting evidence in rebuttal.  However, the court may, as it did in this case, uphold a professional disciplinary panel's judgment even if the panel erred in admitting evidence, if it is clear from the decision that the panel did not take into account inadmissible evidence in reaching its decision.  Our briefing sets out a discussion of the case, White v Nursing and Midwifery Council [2014] EWHC 520 (Admin).