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Miss Angela Hughes:
Professional conduct
panel outcome
Panel decision and reasons on behalf of the
Secretary of State for Education
November 2023
2
Contents
Introduction 3
Allegations 4
Preliminary applications 4
Summary of evidence 5
Documents 5
Witnesses 5
Decision and reasons 5
Findings of fact 6
Panelâs recommendation to the Secretary of State 12
Decision and reasons on behalf of the Secretary of State 15
3
Professional conduct panel decision and recommendations, and decision on
behalf of the Secretary of State
Teacher: Miss Angela Hughes
Teacher ref number: 1283004
Teacher date of birth: 29 November 1974
TRA reference: 18403
Date of determination: 2 November 2023
Former employer: SS Peter and Paulâs Catholic Primary School, Ilford
Introduction
A professional conduct panel (âthe panelâ) of the Teaching Regulation Agency (âthe
TRAâ) convened virtually on 30 October 2023 to 2 November 2023, to consider the case
of Miss Angela Hughes.
The panel members were Mr Terry Hyde (former teacher panellist â in the chair), Ms Jo
Palmer-Tweed (teacher panellist) and Ms Debra Vaughan (lay panellist).
The legal adviser to the panel was Mr Ben Schofield of Blake Morgan LLP.
The presenting officer for the TRA was Ms Holly Quirk of Brown Jacobson LLP.
Miss Hughes was present and was not represented.
The hearing took place in public (save for parts of the evidence considered in private)
and was recorded.
4
Allegations
The panel considered the allegations set out in the notice of proceedings dated 7 August
2023.
It was alleged that Miss Hughes was guilty of unacceptable professional conduct and/or
conduct that may bring the profession into disrepute, in that whilst employed at SS Peter
and Paul's Catholic Primary School, between 1 September 2016 and 15 February 2019,
she:
1. Between September 2016 and October 2018 engaged in inappropriate and/or
unprofessional behaviour on one or more occasions towards one or more pupils,
including by:
a. On or around 24 September 2018, she dragged and/or pulled one or more
pupils to a different area of the Nursery, by their arm;
b. On one or more occasions, she used inappropriate language when referring to
pupils including:
i. âlittle gitsâ and/or âlittle shitsâ
ii. Referring to a pupil as âthickâ
iii. Stating âcould you get him out of my face before I do some serious
damageâ when referring to a pupil.
c. On one or more occasions, she shouted at one or more pupils;
d. On one or more occasions in or around, September 2018, she snatched a toy
and/or toybox from one or more pupils.
2. She failed to take appropriate action and/or ensure appropriate action was taken to
safeguard pupils by, on one or more occasions, condoning children being knocked on the
back of the knee by another member of staff, so they fell.
In a statement of agreed facts, Miss Hughes denied the allegations.
Preliminary applications
Admission of late documents
At the start of the hearing, the panel accepted into the evidence, a six page statement of
agreed facts between the parties.
Privacy
The TRA highlighted that parts of the evidence might touch on [REDACTED] and that the
panel may wish to consider those discrete elements of the evidence in private. This 5
position was not opposed by Miss Hughes. The panel agreed that those elements of the
evidence should be heard in private.
Summary of evidence
Documents
In advance of the hearing, the panel received a bundle of documents which included:
Section 1: Index, chronology and anonymised pupil list â pages 1 to 6
Section 2: Notice of proceedings and response â pages 7 to 16
Section 3: Teaching Regulation Agency witness statements â pages 18 to 29
Section 4: Teaching Regulation Agency documents â pages 30 to 162
Section 5: Teacher documents â pages 163 to 171
In addition, the panel agreed to accept the following:
Statement of agreed facts â pages 172 to 177
The panel members confirmed that they had read all of the documents within the bundle,
in advance of the hearing and the additional document that the panel decided to admit.
Witnesses
The panel heard oral evidence from:
âȘ Witness A ([REDACTED]);
âȘ Witness B ([REDACTED]);
âȘ Witness C ([REDACTED]);
âȘ Witness D ([REDACTED]);
âȘ Miss Angela Hughes (the teacher).
Decision and reasons
The panel announced its decision and reasons as follows:
The panel carefully considered the case before it and reached a decision. Whilst the
panel has considered all of the evidence before it, not every piece of evidence has been
referred to in these reasons. 6
Miss Hughes was employed at SS Peter and Paulâs Catholic Primary School (the
âSchoolâ) as a nursery teacher from 1 September 2016. The children in her class were
âpre-schoolâ and would have been aged three to four years old. This was Miss Hughesâ
second teaching post following her qualification as a teacher in July 2016.
On 24 September 2018, a parent of one of the children in Miss Hughesâ class raised a
concern to the School's [REDACTED] about the way she saw Miss Hughes physically
handling one of the children in the class.
As a result of this, the School started an investigation. This incident and other concerns
raised were looked into. Miss Hughes left the employment of the School following the
conclusion of that investigatory process in February 2019. In May 2019, the School made
a referral to the TRA regarding Miss Hughesâ conduct, which has resulted in this hearing.
Findings of fact
The findings of fact are as follows:
1. Between September 2016 and October 2018 engaged in inappropriate and/or
unprofessional behaviour on one or more occasions towards one or more pupils,
including by:
a. On or around 24 September 2018, you dragged and/or pulled one or more
pupils to a different area of the Nursery, by their arm;
Witness Câs evidence was that a number of her children had previously attended the
School. Her youngest child had [REDACTED] in Miss Hughesâ class that [REDACTED].
At around 11:30-11:45am on [REDACTED], Witness C was standing outside the nursery
waiting to collect her child at the end of the morning. She stated that she looked through
the glass doors of the nursery and could see through to the other side where there was
an outdoor garden used by the nursery.
Witness C stated that she saw Miss Hughes âgrabâ a child by their arm and pull them into
the nursery room from the garden. Witness C further stated, shortly after seeing this, she
witnessed Miss Hughes âgrabâ another child by the arm and also pull them into the
nursery room. Witness C described the two children as just playing like the rest of the
children before Miss Hughes physically handled them.
At this time, Witness C was standing next to Witness D whilst both were looking into the
classroom. She asked Witness D if she âsaw what I just sawâ, and Witness D confirmed
she did. Witness C stated she then reported it to the [REDACTED] who asked her to
provide a written statement of what she had seen. 7
Before the panel was a copy of a letter written by Witness C. It was dated [REDACTED]
and was also stamped âRECEIVED [REDACTED]â. It was addressed to Witness A and
stated that:
âMiss Hughs [sic] had grabbed a child by the arm and pulled them away towards
her. At that point I felt sicked to my stomach and full of fear because does this
happen to my child on a daily basis. This has really upset and scared me in equal
measures and now my confidence in your nursery staff has gone.â
Witness C also stated that she informed the [REDACTED] that Witness D had seen the
events.
Witness Dâs evidence was that her child was in Miss Hughesâ class, and she had
attended the nursery to pick them up at the end of that morning. She was standing
outside the nursery doors talking with other parents. Witness D stated that she saw Miss
Hughes approaching the garden area towards a child who was holding onto a toy trolley.
She then described seeing Miss Hughes harshly take the trolley away from the child and
drag the child back inside to the nursery room. She understood that Witness C was going
to raise the issue with the [REDACTED]. In the following days, the [REDACTED]
contacted her and she provided a written letter which stated:
âWith great shock and sadness we saw a member of nursery staff grab hold of
another child[â]s hand and drag her into the nursery carpet area. Within another
few minutes I observed that the same member of staff again harshly took a trolley
of some sort from another child and again dragged this child into the carpet area.â
In her evidence, Witness A stated that on [REDACTED] she received a phone call from
Witness C who explained that she had been waiting outside of the School and had seen
a concerning incident in the nursery garden through the window. Witness A explained
that Witness C described that she saw Miss Hughes being rough with a child grabbing
and pulling them. Witness A agreed that Witness C would put in writing what she had
seen. Witness C told her that Witness D had also witnessed the event. Witness A stated
she had spoken with Witness D on 24 September 2018 and also asked her to provide a
written account.
Both parentsâ letters included a diagram setting out that they had seen Miss Hughes
pulling a child by their arm in the nursery garden area and Witness C indicated that the
second child who she had seen being pulled by Miss Hughes was just inside the garden
door.
In a disciplinary investigatory meeting on 7 November 2018, Miss Hughes was recorded
as saying that she could not understand how any parent could have a clear view into the
nursery garden from outside. In her written statement to the TRA, Miss Hughes explained
that one of the children had refused to move after hurting another child. However, in her 8
oral evidence before the panel, Miss Hughes stated that she had needed to intervene as
two children were fighting each other.
In assessing this evidence the panel took into account the passage of time since the date
of these events. On that basis, the panel placed significant weight on the
contemporaneous accounts provided at the time. The panel considered that the evidence
of Witness C and Witness D had a level of consistency between each of their accounts
and with the surrounding evidence of the [REDACTED]. The panel noted that Mrs
Hughesâ account had evolved over time, including at this hearing that she was
intervening in two children fighting, which had not been previously mentioned in her
accounts. The panel considered this explanation as unlikely, taking into account the
evidence of Witness C and Witness D who described the children as behaving
unremarkably before Miss Hughes grabbed them.
Accordingly, based on this evidence the panel was satisfied that it was more likely than
not that Miss Hughes had grabbed more than one pupil by the arm to bring them back
into the nursery room at the end of the morning, rather than to prevent fights between
them. The panel considered such actions inappropriate and unprofessional as a method
of controlling the movements of children around the nursery environment.
Therefore, the panel found this allegation proved.
b. On one or more occasions, you used inappropriate language when
referring to pupils including:
i. âlittle gitsâ and/or âlittle shitsâ
ii. Referring to a pupil as âthickâ
iii. Stating âcould you get him out of my face before I do some serious
damageâ when referring to a pupil.
Witness B was [REDACTED] at the School and had been there since [REDACTED]. In
her evidence she described how she worked closely with Miss Hughes on a daily basis.
She stated that on one occasion, whilst in the nursery, she overheard Miss Hughes
saying to Individual E ([REDACTED]) that the children were âlittle shitsâ and âlittle gitsâ.
She said the comments weren't directly aimed at the children, but the children were
within earshot when Miss Hughes made them.
Witness B described another occasion when she was discussing a specific pupil with
Miss Hughes and explaining she was looking forward to him progressing through the
school. Witness B said that Miss Hughes responded along the lines of âit's never going to
happen he's thickâ. Again Witness B was concerned that this was said within earshot of
the children in the nursery. 9
Witness B also gave evidence that on more than one occasion Miss Hughes said to other
staff members words to the effect of âto get children out of her face before she did some
serious damageâ.
Before the panel, was information from the School's investigation which suggested that
when Individual E was interviewed during that process she confirmed that lots of
derogatory language was used about the children in the nursery. It was noted that
Individual E stated that both she and Miss Hughes would refer to the children as âlittle
shitsâ and that she had heard Miss Hughes use the word âgitâ.
Miss Hughes denied these instances. She explained that Witness B had made these
allegations up about her as they did not have a good working relationship. She accepted
that she may have referred to children as âlittle gitsâ but this would have only been in a
social situation not in the classroom.
The panel considered that Witness Bâs recollection was reliable in regards to these
events, as she readily conceded parts she could not fully recall and was able to link
certain events and attribute reasons as to why she could remember specific details about
other instances. Whilst Individual E was not before the panel to give oral evidence and
therefore her remarks in the documentary evidence were hearsay, the panel considered
her account lent support to the reliability of Witness Bâs account.
Accordingly, the panel considered it was more likely than not that Miss Hughes used the
language described in sub-allegations i to iii. The panel considered use of such
language, some of which could be described, in part, as overtly threatening to the
children, as inappropriate and unprofessional.
Therefore the panel found this allegation proved.
c. On one or more occasions, you shouted at one or more pupils;
Witness A explained that on 28 September 2018, she entered the nursery through the
garden rather than the main door and that Miss Hughes was not aware that she had
entered the nursery. She described that Miss Hughes was shouting at the children in an
uncontrolled manner and the children looked frightened as a result.
Witness B stated in her evidence that she would regularly raise her voice in front of the
children in the nursery.
Miss Hughes explained that she would raise her voice in front of the children on
occasions, but this did not occur on 28 September, but rather on 17 September. She
explained that following a [REDACTED] and [REDACTED], she was overwhelmed and
about to burst into tears. She denied it was a regular occurrence that she raised her
voice at the children. 10
The panel was satisfied that the accounts of Witness B and Witness A and the
surrounding evidence demonstrated how Miss Hughes would interact with the children.
This suggested it was more likely than not that, on more than one occasion, Miss Hughes
had shouted at the children. The panel considered this was inappropriate and
unprofessional as a method of communicating with children of such a young age.
Accordingly the panel found this allegation proved.
d. On one or more occasions in or around, September 2018, you snatched a
toy and/or toybox from one or more pupils.
In their accounts, both Witness C and Witness D described Miss Hughes pulling away the
toybox (or trolley) from one of the children.
Witness Aâs evidence was that when she entered the nursery on 28 September, she also
witnessed Miss Hughes snatching a toybox away from a child and forcibly throwing the
toys into the box.
Miss Hughes accepted that on an occasion she did snatch a toybox from a child on 17
September, which occurred whilst she was overwhelmed by her [REDACTED].
The panel considered that the evidence showed it was more likely than not Miss Hughes
had snatched toys from more than one pupil during September and therefore the panel
found this allegation proved.
2. You failed to take appropriate action and/or ensure appropriate action was taken
to safeguard pupils by, on one or more occasions, condoning children being
knocked on the back of the knee by another member of staff, so they fell.
Witness Bâs evidence was that on occasions she saw Individual E attempting to get the
children to sit down by kicking the back of the childrenâs legs so they fell, albeit it was
done in a âjokeyâ manner rather than maliciously. She described how Miss Hughes would
laugh during these instances.
Miss Hughesâ evidence was that she had no concerns regarding Individual Eâ interactions
with the children. She recalled there was one child who she described as a âdrama
queenâ and who would laugh and roll around on the floor as a result of Individual Eâ
actions.
The panel considered that as Witness Bâs evidence was credible in other areas, it lent to
her reliability in her recollection of these events. Even if Individual Eâ actions were
undertaken in a âjokeyâ manner, it was an inappropriate method of enforcing the
instructions given to the children. This was particularly as the children, at that age, are
unable to distinguish between reality or make believe, so at best this would have been
poor modelling. The panel considered that as the senior member of staff in the nursery, 11
Miss Hughes held the ultimate responsibility for addressing the inappropriate actions of
her more junior staff. By not dealing with Individual Eâ inappropriate actions she failed in
her safeguarding duties.
Therefore the panel found this allegation proved.
Findings as to unacceptable professional conduct and/or conduct that
may bring the profession into disrepute
Having found the allegations proved, the panel went on to consider whether the facts of
those proved allegations amounted to unacceptable professional conduct and/or conduct
that may bring the profession into disrepute.
In doing so, the panel had regard to the document Teacher Misconduct: The Prohibition
of Teachers, which is referred to as âthe Adviceâ.
The panel was satisfied that the conduct of Miss Hughes in relation to the facts found
proved, involved breaches of the Teachersâ Standards. The panel considered that, by
reference to Part 2, Miss Hughes was in breach of the following standards.
âȘ Teachers uphold public trust in the profession and maintain high standards of
ethics and behaviour, within and outside school, by
o treating pupils with dignity, building relationships rooted in mutual respect,
and at all times observing proper boundaries appropriate to a teacherâs
professional position
o having regard for the need to safeguard pupilsâ well-being, in accordance
with statutory provisions
âȘ Teachers must have proper and professional regard for the ethos, policies and
practices of the school in which they teach
âȘ Teachers must have an understanding of, and always act within, the statutory
frameworks which set out their professional duties and responsibilities.
The panel also considered whether Miss Hughesâ conduct displayed behaviours
associated with any of the offences listed on pages 12 to 14 of the Advice. The Advice
indicates that where behaviours associated with such an offence exist, a panel is likely to
conclude that an individualâs conduct would amount to unacceptable professional
conduct. The panel found that none of these offences was relevant.
The panel considered that the evidence demonstrated a regular pattern of behaviour in
the presence of children which was not acceptable. The seriousness of these actions
was aggravated by the very young age of the children who are more reliant on their
teachers and more impressionable than children of an older age. 12
The panel has considered each of the allegations separately and considered they each
cross the threshold into serious misconduct. If the panel had found that Miss Hughesâ
comments about the children being âlittle gitsâ had taken place away from the children, it
would have considered it as being below the threshold. However, as it was within their
earshot, the panel considered this factor crossed the threshold into serious misconduct.
In her evidence Miss Hughes asserted that she had not received any positive handling
training. The panel considered this was unlikely given the evidence of training given at
the School. Nonetheless the panel considered that even without this training a teacher
should not consider it as acceptable to move a young child by grabbing or pulling at their
arm, or their jumper as Miss Hughes asserted in her evidence in relation to 24 September
2018.
The panel was therefore satisfied that the conduct of Miss Hughes amounted to
misconduct of a serious nature which fell significantly short of the standards expected of
the profession.
Accordingly, the panel was satisfied that Miss Hughes was guilty of unacceptable
professional conduct.
The panel took into account the way the teaching profession is viewed by others and
considered the influence that teachers may have on pupils, parents and others in the
community. The panel also took account of the uniquely influential role that teachers can
hold in pupilsâ lives and the fact that pupils must be able to view teachers as role models
in the way that they behave.
The findings of misconduct are serious, and the conduct displayed would be likely to
have a negative impact on the individualâs status as a teacher, potentially damaging the
publicâs perception. Parents and the community place their utmost trust in teachers whilst
children are in their care. In this case, there was evidence of parents being concerned
about leaving their children in the care of the School after seeing Miss Hughes act in the
way she did. This was a clear example of how the reputation of the teaching profession
might be significantly weakened, if that fundamental trust were broken.
The panel therefore found that Miss Hughesâ actions constituted conduct that may bring
the profession into disrepute.
Panelâs recommendation to the Secretary of State
Given the panelâs findings in respect of unacceptable professional conduct and conduct
that may bring the profession into disrepute, it was necessary for the panel to go on to
consider whether it would be appropriate to recommend the imposition of a prohibition
order by the Secretary of State. 13
In considering whether to recommend to the Secretary of State that a prohibition order
should be made, the panel had to consider whether it would be an appropriate and
proportionate measure, and whether it would be in the public interest to do so. Prohibition
orders should not be given in order to be punitive, or to show that blame has been
apportioned, although they are likely to have punitive effect.
The panel had regard to the particular public interest considerations set out in the Advice
and, having done so, found a number of them to be relevant in this case, namely:
âȘ the protection of pupils;
âȘ the maintenance of public confidence in the profession;
âȘ declaring and upholding proper standards of conduct;
In the light of the panelâs findings against Miss Hughes which involved inappropriate
physical handling of pupils, inappropriate verbal communications and failures in
safeguarding, there was a public interest consideration in respect of the protection of
pupils. Similarly, the panel considered that public confidence in the profession could be
weakened if conduct such as that found against Miss Hughes were not treated with the
utmost seriousness when regulating the conduct of the profession. The panel was of the
view that a public interest consideration in declaring proper standards of conduct in the
profession was also present as the conduct found against Miss Hughes was outside that
which could reasonably be tolerated.
In view of the clear public interest considerations that were present, the panel considered
carefully whether or not it would be proportionate to impose a prohibition order, taking
into account the effect that this would have on Miss Hughes.
In carrying out the balancing exercise, the panel had regard to the public interest
considerations both in favour of, and against, prohibition as well as the interests of Miss
Hughes. The panel took further account of the Advice, which suggests that a prohibition
order may be appropriate if certain behaviours of a teacher have been proved. In the list
of such behaviours, those that were relevant in this case were:
âȘ serious departure from the personal and professional conduct elements of the
Teachersâ Standards;
âȘ misconduct seriously affecting the education and/or safeguarding and well-being
of pupils, and particularly where there is a continuing risk;
âȘ abuse of position or trust (particularly involving pupils);
âȘ failure in their duty of care towards a child, including exposing a child to risk or
failing to promote the safety and welfare of the children (as set out in Part 1 of
KCSIE); 14
Even though some of the behaviour found proved in this case indicated that a prohibition
order would be appropriate, the panel went on to consider the mitigating factors.
Mitigating factors may indicate that a prohibition order would not be appropriate or
proportionate.
The panel considered there was no evidence to suggest that Miss Hughesâ actions were
not deliberate or that she was acting under duress. Miss Hughes did not provide the
panel with any documentary evidence or character references attesting to her abilities as
an educator.
Miss Hughes did explain to the panel that although she was not currently working in the
education sector, she had continued to keep up to date with good teaching practices.
The panel took into account the evidence of other members of staff from the School,
which suggested there were ongoing concerns about Miss Hughesâ practice. The panel
also took into account the evidence from Witness C who stated that prior to the incident
on 24 September 2018, she had no concerns about Miss Hughes and initially had found
her to be professional and was reassured that her child would be âin safe handsâ.
Miss Hughesâ evidence was that at the time of these allegations, [REDACTED]. The
panel considered that Miss Hughesâ misconduct could not be categorised as an isolated
incident or momentary lapse. The panel had significant concerns about a risk of repetition
of such misconduct should Miss Hughes return to the classroom at this point in time.
The panel first considered whether it would be proportionate to conclude this case with
no recommendation of prohibition, considering whether the publication of the findings
made by the panel would be sufficient.
The panel was of the view that, applying the standard of the ordinary intelligent citizen, it
would not be a proportionate and appropriate response to recommend no prohibition
order. Recommending that the publication of adverse findings would be sufficient would
unacceptably compromise the public interest considerations present in this case, despite
the severity of the consequences for Miss Hughes of prohibition.
The panel was of the view that prohibition was both proportionate and appropriate. The
panel decided that the public interest considerations outweighed the interests of Miss
Hughes. The current risk of repetition of similar misconduct was the significant factor in
forming that opinion. Accordingly, the panel made a recommendation to the Secretary of
State that a prohibition order should be imposed with immediate effect.
The panel went on to consider whether or not it would be appropriate for it to decide to
recommend a review period of the order. The panel was mindful that the Advice states
that a prohibition order applies for life, but there may be circumstances, in any given
case, that may make it appropriate to allow a teacher to apply to have the prohibition
order reviewed after a specified period of time that may not be less than two years. 15
The Advice indicates that there are behaviours that, if proved, would militate against the
recommendation of a review period. The panel did not consider any of these factors as
being relevant in this case.
The panel considered that Miss Hughes was not incapable of remediating the current
risks in this case. The panel envisaged that with clear evidence of an increased
understanding of positive handling, behaviour management of pupils and self-regulation
in the classroom in line with professional expectations, Miss Hughes might be able to
suitably ameliorate those risks.
The panel decided that these findings indicated a situation in which a review period
would be appropriate and, as such, decided that it would be proportionate, in all the
circumstances, for the prohibition order to be recommended with provision for a review
period after two years.
Decision and reasons on behalf of the Secretary of State
I have given very careful consideration to this case and to the recommendation of the
panel in respect of both sanction and review period.
In considering this case, I have also given very careful attention to the Advice that the
Secretary of State has published concerning the prohibition of teachers.
In this case, the panel has found all of the allegations proven and found that those
proven facts amount to unacceptable professional conduct and conduct that may bring
the profession into disrepute.
The panel has made a recommendation to the Secretary of State that Miss Hughes
should be the subject of a prohibition order, with a review period of two years.
In particular, the panel has found that Miss Hughes in breach of the following standards:
âȘ Teachers uphold public trust in the profession and maintain high standards of
ethics and behaviour, within and outside school, by
o treating pupils with dignity, building relationships rooted in mutual respect,
and at all times observing proper boundaries appropriate to a teacherâs
professional position
o having regard for the need to safeguard pupilsâ well-being, in accordance
with statutory provisions
âȘ Teachers must have proper and professional regard for the ethos, policies and
practices of the school in which they teach 16
âȘ Teachers must have an understanding of, and always act within, the statutory
frameworks which set out their professional duties and responsibilities.
The panel was satisfied that the conduct of Miss Hughes involved breaches of the
responsibilities and duties set out in statutory guidance Keeping children safe in
education (KCSIE), namely failure in the duty of care towards a child, including exposing
a child to risk or failing to promote the safety and welfare of the children (as set out in
Part 1 of KCSIE).
The panel finds that the conduct of Miss Hughes fell significantly short of the standards
expected of the profession.
The findings of misconduct are particularly serious as they include inappropriate physical
handling of pupils, inappropriate verbal communications and failures in safeguarding.
I have to determine whether the imposition of a prohibition order is proportionate and in
the public interest. In considering that for this case, I have considered the overall aim of a
prohibition order which is to protect pupils and to maintain public confidence in the
profession. I have considered the extent to which a prohibition order in this case would
achieve that aim taking into account the impact that it will have on the individual teacher.
I have also asked myself, whether a less intrusive measure, such as the published
finding of unacceptable professional conduct and conduct likely to bring the profession
into disrepute, would itself be sufficient to achieve the overall aim. I have to consider
whether the consequences of such a publication are themselves sufficient. I have
considered therefore whether or not prohibiting Miss Hughes, and the impact that will
have on the teacher, is proportionate and in the public interest.
In this case, I have considered the extent to which a prohibition order would protect
children and safeguard pupils. The panel has observed that âthe evidence demonstrated
a regular pattern of behaviour in the presence of children which was not acceptable. The
seriousness of these actions was aggravated by the very young age of the children who
are more reliant on their teachers and more impressionable than children of an older
age.â A prohibition order would therefore prevent such a risk from being present in the
future.
The panel does not comment directly on whether Miss Hughes showed insight and
remorse. However Miss Hughes denied the allegations and the panel said that it âhad
significant concerns about a risk of repetition of such misconduct should Miss Hughes
return to the classroom at this point in time.â In my judgement, the lack of evidence of
insight and remorse means that there is some risk of the repetition of this behaviour and
this puts at risk the future wellbeing of pupils. I have therefore given this element
considerable weight in reaching my decision.
I have gone on to consider the extent to which a prohibition order would maintain public
confidence in the profession. The panel observe, âThe findings of misconduct are 17
serious, and the conduct displayed would be likely to have a negative impact on the
individualâs status as a teacher, potentially damaging the publicâs perception. Parents and
the community place their utmost trust in teachers whilst children are in their care. In this
case, there was evidence of parents being concerned about leaving their children in the
care of the School after seeing Miss Hughes act in the way she did. This was a clear
example of how the reputation of the teaching profession might be significantly
weakened, if that fundamental trust were broken.â I am particularly mindful of the finding
of inappropriate handling of children and inappropriate language in this case and the
impact that such a finding has on the reputation of the profession.
I have had to consider that the public has a high expectation of professional standards of
all teachers and that the public might regard a failure to impose a prohibition order as a
failure to uphold those high standards. In weighing these considerations, I have had to
consider the matter from the point of view of an âordinary intelligent and well-informed
citizen.â
I have considered whether the publication of a finding of unacceptable professional
conduct and conduct likely to bring the profession into disrepute in the absence of a
prohibition order, can itself be regarded by such a person as being a proportionate
response to the misconduct that has been found proven in this case.
I have also considered the impact of a prohibition order on Miss Hughes. The panel
comment:
âMiss Hughes did not provide the panel with any documentary evidence or character
references attesting to her abilities as an educator.â
âMiss Hughes did explain to the panel that although she was not currently working in the
education sector, she had continued to keep up to date with good teaching practices.â
âThe panel took into account the evidence of other members of staff from the School,
which suggested there were ongoing concerns about Miss Hughesâ practice.â
A prohibition order would prevent Miss Hughes from teaching. A prohibition order would
also clearly deprive the public of her contribution to the profession for the period that it is
in force.
In this case, I have placed considerable weight on the panelâs comments that the Advice
suggests that a prohibition order may be appropriate if certain behaviours of a teacher
have been proved, and that behaviours relevant in this case included:
âȘ serious departure from the personal and professional conduct elements of the
Teachersâ Standards; 18
âȘ misconduct seriously affecting the education and/or safeguarding and well-being
of pupils, and particularly where there is a continuing risk;
âȘ abuse of position or trust (particularly involving pupils);
âȘ failure in their duty of care towards a child, including exposing a child to risk or
failing to promote the safety and welfare of the children (as set out in Part 1 of
KCSIE).
I have also placed considerable weight on the finding of the panel that âthe public interest
considerations outweighed the interests of Miss Hughes. The current risk of repetition of
similar misconduct was the significant factor in forming that opinion. Accordingly, the
panel made a recommendation to the Secretary of State that a prohibition order should
be imposed with immediate effect.â
I have given less weight in my consideration of sanction therefore, to the contribution that
Miss Hughes has made to the profession. In my view, it is necessary to impose a
prohibition order in order to maintain public confidence in the profession. A published
decision, in light of the circumstances in this case, that is not backed up by insight and
remorse, does not in my view satisfy the public interest requirement concerning public
confidence in the profession.
For these reasons, I have concluded that a prohibition order is proportionate and in the
public interest in order to achieve the intended aims of a prohibition order.
I have gone on to consider the matter of a review period. In this case, the panel has
recommended a two-year review period.
I have considered the panelâs comments, âThe panel considered that Miss Hughes was
not incapable of remediating the current risks in this case. The panel envisaged that with
clear evidence of an increased understanding of positive handling, behaviour
management of pupils and self-regulation in the classroom in line with professional
expectations, Miss Hughes might be able to suitably ameliorate those risks.â The panel
recommended that a review period of two years would be proportionate to the
circumstances in this case.
I have decided that a two-year review period is proportionate and is required to satisfy
the maintenance of public confidence in the profession.
This means that Miss Angela Hughes is prohibited from teaching indefinitely and
cannot teach in any school, sixth form college, relevant youth accommodation or
childrenâs home in England. She may apply for the prohibition order to be set aside, but
not until 17 November 2025, two years from the date of this order at the earliest. This is
not an automatic right to have the prohibition order removed. If she does apply, a panel
will meet to consider whether the prohibition order should be set aside. Without a
successful application, Miss Hughes remains prohibited from teaching indefinitely. 19
This order takes effect from the date on which it is served on the teacher.
Miss Hughes has a right of appeal to the King's Bench Division of the High Court within
28 days from the date she is given notice of this order.
Decision maker: David Oatley
Date: 10 November 2023
This decision is taken by the decision maker named above on behalf of the Secretary of
State.
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