West London Mental Health NHS Trust v Chhabra [2013] EWCA Civ 11

The appellant NHS Trust appealed against an injunction preventing it from referring to a disciplinary hearing the alleged breaches of confidentiality by the respondent employee, Dr Chhabra, a consultant psychiatrist. There had been a complaint about Dr Chhabra reading and dictating patient notes whilst on public transport. A civil servant overheard Dr Chhabra and complained to the Trust.

Dr Chhabra largely admitted the patient confidentiality breaches, apologised, and promised that there would be no repeats in future. Under the disciplinary procedure relating to conduct, an investigating officer was appointed, who upheld the confidentiality breaches. A case manager decided to refer charges