Lambert J dismisses judicial review challenging GMC’s regulation of medical associates

05/09/25

On 5 September 2025, Lambert J handed down judgment in Anaesthetists United; Chesterton v General Medical Council, a judicial review claim which alleged that the GMC’s regulation of medical associates (both Physician Associates (PAs) and Anaesthesia Associates (AAs)) is unlawful and unsafe. The claim was brought by a doctors’ advocacy body and the parents of Emily Chesterton, who tragically died in November 2022 after a PA working in her GP surgery misdiagnosed a pulmonary embolism and failed to refer her to hospital.

At the end of 2024, the GMC assumed regulatory responsibility for associates, who are not medically qualified and whose numbers are forecast to rise from the low thousands at present to 16,000 by 2030. The claim alleged that the GMC is failing on an ongoing basis adequately to respond to the systemic risks to patient safety posed by the deployment of associates. In particular, the claimants alleged that the GMC ought to have imposed limits on the practice of associates, ensured that associates are safely supervised by doctors and that they inform patients that they are not a doctor, in order that patients can give informed consent.

Lambert J found that the GMC had not acted irrationally, either from the point of view of procedural or outcome irrationality. She found that it was not irrational simply to extend to associates the same model of regulation that applies to doctors, despite the fundamental differences between the two professions. Whilst recognising that there are patient safety advantages to the introduction of fixed limits on the practice of associates and that the GMC’s advice on how associates ought to introduce themselves (which does not explicitly require them to tell patients that they are not a doctor) could be clearer, she found that the GMC had been entitled to take the approach that it did.

The judgment is available here.