In a professional discipline motion, the member sought to quash a notice of hearing on the basis that the alleged misconduct occurred before registration.
The Panel held that the Discipline Committee has jurisdiction over pre-membership conduct where a broad and purposive reading of the governing statute, informed by the College's public protection mandate, supports that result.
The Panel rejected the submission that the registration regime exhaustively addresses pre-registration misconduct and held that the presumption against retrospectivity does not bar jurisdiction in this public protection context.
It adopted a suitability-based threshold, holding that jurisdiction extends to pre-membership conduct that calls into question the member's current suitability to practise.