A dentist who was struck off the professional register after sending a series of racially motivated emails disparaging Indian dentistry has successfully challenged her erasure in the High Court, with a judge ruling that her conduct, whilst seriously wrong, did not warrant a permanent ban from practising.
Hanna Grzelczak, 48, a Polish-qualified dentist based in Southampton who has worked in the UK since 2009, sent four emails to staff at Damira Dental Studios in Fareham, Hampshire, in the summer of 2023, following her resignation from the practice. In the messages, she asked for her name to be removed from the company’s website and online materials, making a series of remarks that a fitness to practise panel later found to be unprofessional, inappropriate and racially motivated.
In one email, Ms Grzelczak wrote that she felt “low” about being associated with Damira, describing it as an “Indian company” providing “NHS low quality service,” and adding that she did not wish to be connected with “Indian dentistry.” She contrasted this with what she described as her own provision of “German technology” implants.
A complaint was filed with the General Dental Council, and four allegations — each relating to one of the emails — were brought before a professional conduct committee. Ms Grzelczak admitted all four allegations at the outset of the three-day hearing in September 2025. The committee nonetheless moved to erase her name from the dental register, finding that her conduct reflected a “deep-seated and harmful personality or professional attitudinal issue” and that she had failed to fully grasp the offensiveness of her remarks, having described them at various points as “illogical,” “nonsense” and “silly.”
Ms Grzelczak mounted a High Court appeal, and Judge Bilal Siddique found in her favour. He accepted that her emails had been “plainly offensive, inappropriate and racially motivated” and that she had “lashed out in anger, using racist comments because she knew they would be hurtful.” However, he concluded that the threshold for erasure had not been met.
The judge noted that the emails had not involved patients and had not given rise to any direct risk to patient safety or clinical care. He found that while her explanations had at times been inadequate and reflected attempts to minimise her conduct, they did not demonstrate the kind of “entrenched or enduring refusal to acknowledge wrongdoing” that would justify permanent removal from the register.
“Erasure is reserved for behaviour fundamentally incompatible with continued registration,” Judge Siddique said, adding that the evidence “falls materially short of establishing the kind of sustained, deep-seated attitudinal defect or persistent lack of insight” that would make erasure proportionate in this case.
The sanction of erasure was accordingly substituted with a six-month suspension. Ms Grzelczak is now eligible to return to practice once that period has elapsed.
