The General Medical Council (GMC) is consulting on new guidance concerning doctors’, physician associates’ and anaesthesia associates’ personal beliefs and medical practice. The draft guidance addresses how healthcare professionals may express personal beliefs, discuss conscientious objections, and interact with patients on issues involving religion, ethics and identity. While the GMC says the guidance aims to balance patient care with professional responsibilities, there are serious concerns that parts of the draft could undermine freedom of religion and conscience for Christian healthcare professionals and create a chilling effect on the expression of sincerely held beliefs in clinical settings.
We encourage supporters to respond to the consultation by the June 11 deadline. All members of the public are welcome to respond to the consultation. You do not have to be a medical professional to participate. You also do not need to answer every question in order to take part.
Respond to the consultation here
Why the GMC guidance matters: lessons from Dr Richard Scott and Dr Dermot Kearney
Recent cases involving Christian doctors demonstrate how unclear or ideologically driven guidance can lead to unjust regulatory action against Christian medical professionals who actively live out their faith. Dr Richard Scott faced years of investigation after offering to pray with a patient following a consultation, despite the patient initially expressing no objection and despite findings that there was no evidence of harm. Similarly, Dr Dermot Kearney was subjected to severe sanctions after prescribing life-saving abortion reversal treatment to women who regretted taking the first abortion pill. In both cases, concerns about professional boundaries and personal beliefs were used to justify intrusive regulatory action against doctors acting according to their Christian convictions and professional judgment.
These cases illustrate why the GMC’s proposed guidance matters. Ambiguous or overly restrictive rules on personal beliefs risk creating a chilling effect where Christian healthcare professionals fear investigation, disciplinary action, or career damage simply for expressing lawful beliefs or acting according to conscience. This not only threatens freedom of religion and expression, but can also undermine compassionate patient care and open clinical discussion. Importantly, both Dr Scott and Dr Kearney were ultimately vindicated after prolonged legal and regulatory battles, highlighting the danger of guidance that allows subjective complaints or ideological disagreement to become the basis for professional misconduct proceedings. Indeed, in Dr Kearney’s case, because of his courage, medical expertise, and Christian convictions, babies are alive today who otherwise may never have been born.
The proposed guidance risks greater restrictions on Christian doctors
The GMC’s proposed guidance appears in several respects to be more restrictive than the existing framework governing doctors’ personal beliefs and practice. Rather than providing clear protections for freedom of religion and conscience, the draft guidance adopts broad and subjective language that could make Christian healthcare professionals more vulnerable to complaints, intrusive investigations, and disciplinary action, even where no patient harm has occurred. At the same time, the guidance is notably muted on several key issues that have arisen in recent years, including the disproportionate scrutiny faced by doctors who express Christian beliefs, offer prayer appropriately, or act according to conscience in ethically sensitive areas of medicine. The experiences of doctors such as Richard Scott and Dermot Kearney demonstrate the serious personal and professional consequences that can follow when regulators fail to provide robust safeguards against ideologically motivated complaints. Although both men were ultimately vindicated, the lengthy period of investigation and sanction they endured underline why the GMC must ensure that its guidance explicitly protects lawful religious expression and conscientious medical practice.
Guidance on draft answers
Below are some of the most important issues discussed in the GMC consultation. We encourage supporters to respond in their own words wherever possible, but the draft answers below provide a useful starting point reflecting the concerns raised by the Christian Legal Centre about freedom of religion, freedom of expression, and freedom of conscience in healthcare in its consultation response.
The questions and draft answers below are therefore organised around the main issues raised by the consultation rather than reproducing the consultation questions verbatim, as the wording and structure of the GMC’s questions do not readily lend themselves to clear template responses.
- Protecting doctors’ freedom to express personal beliefs appropriately [applicable to questions 4,11 and 26 of the consultation]
Healthcare professionals do not surrender their fundamental rights to freedom of religion and expression when they enter the workplace. Christian doctors and medical professionals should be free to express personal beliefs respectfully and appropriately, provided this does not involve coercion or harassment. Compassionate discussions about faith, conscience and ethics can form a legitimate part of holistic patient care.
- Ensuring doctors can discuss faith and belief sensitively with patients [applicable to questions 4, 11, 26 and 27 of the consultation]
The guidance should more clearly protect lawful religious expression and voluntary conversations initiated or welcomed by patients. The current draft risks creating a chilling effect where doctors fear complaints simply for offering support, including prayer, or discussing matters of faith sensitively and appropriately. Cases such as Dr Richard Scott demonstrate how vague standards can lead to disproportionate investigations despite no evidence of patient harm.
- Preventing subjective offence from becoming grounds for discipline [applicable to questions 11, 23 and 24 of the consultation]
Doctors should always communicate sensitively and professionally. However, subjective offence alone should not become the basis for disciplinary action. In a diverse society, lawful expressions of Christian belief may sometimes be disagreed with or considered unwelcome by others. The guidance must distinguish clearly between genuine misconduct and the respectful expression of protected beliefs.
- Safeguarding freedom of conscience in ethically contested areas of medicine [applicable to questions 11, 24, 26 and 27 of the consultation]
The guidance should provide stronger protections for freedom of conscience, particularly in ethically contested areas such as abortion, end-of-life decisions and transgender issues. Christian doctors should not face professional disadvantage or regulatory scrutiny for acting according to deeply held religious or ethical convictions within the law. Freedom of conscience is a fundamental democratic right and an important safeguard within medicine.
- Achieving a fair balance between patient care and doctors’ fundamental rights [applicable to questions 11, 23 and 26 of the consultation]
The draft guidance appears weighted, and vague on specific issues, in a way which is detrimental to healthcare professionals with traditional Christian beliefs and fails to give adequate protection to the fundamental freedoms guaranteed under Articles 9 and 10 of the European Convention on Human Rights, including freedom of religion and freedom of expression. While patient care is paramount, Christian doctors should not be made to feel that expressing biblical beliefs, offering compassionate spiritual support, or acting according to conscience places their careers at risk. The guidance risks creating a culture where faithful Christian professionals feel pressured to remain silent about their beliefs or withdraw entirely from areas of medicine involving difficult ethical issues.
There is growing concern among Christian healthcare professionals that regulators increasingly treat orthodox Christian beliefs as a potential professional problem rather than a protected freedom. Existing professional standards already prohibit coercion, harassment and discrimination, meaning there is no need for further restrictions that could be used to justify complaints, intrusive investigations or disciplinary proceedings against doctors who have caused no harm. Too often, Christian doctors have faced years of stress, reputational damage and threats to their livelihoods simply for living and working consistently with their faith. The GMC should send a clear message that Christian healthcare professionals are valued within the NHS and wider medical profession, and that lawful expressions of faith and conscience must be robustly protected rather than viewed with suspicion.
- Providing clear guidance that does not encourage regulatory overreach [applicable to questions 11, 23, 24 and 26 of the consultation]
The guidance would benefit from the inclusion of clearer practical examples addressing the real situations increasingly faced by Christian healthcare professionals. Without this clarity, there is a risk that doctors will be left uncertain about what is permitted and fearful that ordinary professional interactions could result in complaints or regulatory scrutiny. The GMC should include balanced examples dealing with issues such as the use of preferred pronouns and “misgendering”, conscientious objections to participation in transgender medical interventions, discussions concerning abortion and end-of-life care, and the appropriate expression of Christian faith in conversations with patients.
Providing realistic examples would help ensure the guidance is applied fairly and consistently while giving healthcare professionals greater confidence to practise medicine lawfully and ethically in accordance with their conscience. It would also help prevent situations where Christian doctors are subjected to unnecessary investigations or disciplinary proceedings despite acting professionally, compassionately and in the best interests of patients. The guidance should make clear that lawful expressions of Christian belief and conscientious medical practice are not in themselves indicators of professional misconduct.
- Protecting patients without treating Christian belief as inherently harmful [applicable to questions 11 and 26 of the consultation]
Patient safety, dignity and respectful care must always remain central to medical practice. However, the GMC should take care to ensure that the guidance is not interpreted or applied in ways that disproportionately disadvantage Christian healthcare professionals or discourage lawful expressions of faith and conscience. Many Christian doctors are concerned that, in practice, vague standards can too easily become the basis for complaints or disciplinary referrals arising from disagreement with sincerely held biblical beliefs rather than from any actual misconduct or patient harm.
Doctors are already bound by extensive professional obligations requiring them to treat patients with respect, compassion and fairness regardless of background or belief. The guidance should therefore focus on promoting clarity, proportionality and genuine patient welfare rather than creating an atmosphere where healthcare professionals feel unable to speak honestly about ethical issues or live consistently with their Christian convictions. Overly restrictive approaches risk damaging trust between doctors and patients, discouraging open conversations and pushing faithful Christian professionals out of vital areas of medical practice.
- Learning from past cases where Christian doctors were wrongly investigated [applicable to questions 11, 23, 26 and 27 of the consultation]
The GMC should reflect carefully on recent cases in which Christian healthcare professionals have faced lengthy investigations or professional scrutiny arising from the expression of lawful religious beliefs or conscientious practice, even where concerns about patient harm were ultimately not upheld. These cases demonstrate the importance of ensuring that guidance in this area is clear, balanced and applied proportionately. The final guidance should therefore contain stronger assurances that freedom of religion, freedom of expression and lawful conscientious medical practice will be properly respected and protected within professional regulation.
- Protecting freedom of conscience on compelled pronoun use [applicable to questions 13, 24 and 26 of the consultation]
The GMC should provide clearer assurances that healthcare professionals will not face disciplinary action for declining to use compelled language that conflicts with their Christian beliefs or understanding of biological reality. While doctors should always communicate with patients respectfully and sensitively, respectful communication should not require medical professionals to affirm beliefs about gender identity or transgenderism that they do not hold in conscience. Many Christian doctors are concerned that uncertainty surrounding preferred pronouns and “misgendering” could expose them to complaints or professional sanctions despite acting politely, professionally and without any intention to cause offence.
The guidance should recognise that there are lawful and legitimate differences of belief on issues relating to sex and gender, including Biblically grounded beliefs and the understanding that sex is immutable. Doctors should remain free to use accurate biological language and exercise professional judgment without fear that this alone could trigger regulatory scrutiny. The GMC should ensure that the final guidance protects both respectful patient care and the fundamental rights of healthcare professionals to freedom of religion, belief and expression.
- Protecting freedom of conscience and opposition to mandatory signposting [applicable to questions 11, 24 and 26 of the consultation]
The GMC should ensure that healthcare professionals are not compelled to participate, either directly or indirectly, in procedures or treatments that conflict with their deeply held Christian beliefs and ethical convictions. This includes concerns relating to abortion, assisted suicide and transgender medical interventions. In particular, the guidance should avoid imposing mandatory “signposting” requirements that force doctors to facilitate or promote services they believe to be morally wrong or harmful. Requiring a doctor to actively direct a patient towards a procedure to which they conscientiously object risks undermining the very purpose of conscience protections in medicine.
Christian healthcare professionals should be able to practise medicine with integrity while continuing to provide compassionate and professional care to all patients. The guidance should therefore recognise that freedom of conscience includes not only the right to refuse direct participation in certain procedures, but also protection from being compelled to arrange, recommend or endorse them. A fair and balanced approach should respect both patient care and the fundamental rights of doctors to act consistently with their faith and conscience without fear of professional sanction.
The draft guidance should also recognise that protections for freedom of conscience are not limited only to situations where they are explicitly set out in statute or professional regulation. The Human Rights Act and Article 9 of the European Convention on Human Rights require that genuine Christian convictions concerning conscience and religious belief are properly respected and accommodated whenever they arise within professional life.
- Respecting parental rights and allowing access to alternative care for children [applicable to questions 17 and 24 of the consultation]
The guidance should place greater emphasis on the important role of parents in making decisions concerning the medical care of their children, particularly in complex and ethically sensitive areas of treatment, such as end-of-life matters. Parents are ordinarily best placed to act in the interests of their children and should be treated as partners in care rather than obstacles to clinical decision-making.
Where lawful and available, parents should be free to seek alternative care options without undue obstruction or pressure from medical professionals or institutions. The guidance should encourage respectful dialogue, openness to second opinions and proper recognition of parental rights and responsibilities. In difficult medical situations, healthcare professionals should seek to work collaboratively with families wherever possible and avoid approaches that unnecessarily escalate conflict or exclude parents from important decisions concerning their children’s welfare.