The respondent admitted the alleged conduct, and that it constituted professional misconduct, with the exception of her state of knowledge in relation to the client's inappropriate conduct. She also disputed the entry into evidence of her solicitor's letter, which formed the basis of the allegation regarding providing false and misleading information to the Board, because it was marked as 'without prejudice'.

The respondent also disputed the length of disqualification sought by the Board and submitted that the period sought by the Board was only warranted in matters involving extremely severe exploitation and proportionately severe harm which could be distinguished from this matter.

Held, finding professional misconduct and imposing sanctions:

• The respondent has engaged in professional misconduct pursuant to s 196(1)(b)(ii) of the National Law;
• The respondent is reprimanded;
• The respondent is disqualified from applying for registration as a health practitioner for a period of six years;
• The respondent is prohibited from providing any health services in any capacity during the period of disqualification and until such time as she is registered as a health practitioner.

Health practitioners -- Complaint by the Nursing and Midwifery Board of Australia -- Professional misconduct -- Sexual misconduct in connection with the practice of medicine - Boundary violation -- False and misleading statements to authorities -- Reprimand - Disqualified from applying for registration for 6 years - Prohibited from providing any health services until re-registered as a health practitioner

Health Practitioner Regulation National Law (South Australia) Act 2010 sch 2 ss 5, 193

Craig v Medical Board of South Australia [2001] SASC 169; (2001) 79 SASR 545

Davies v Nyland (1974) 10 SASR 76

Health Care Complaints Commission v Litchfield (1997) 41 NSWLR 630

Marin v Chiropractic Board of Australia [2020] SASCFC 74

Bar Association NSW v Evatt [1968] HCA 20; (1968) 117 CLR 177

Nursing and Midwifery Board of Australia v Farrow (Review and Regulation) [2022] VCAT 43

Briginshaw v Briginshaw [1938] HCA 34; (1938) 60 CLR 336

Pharmacy Board of Australia v Roberts [2022] SACAT 111

This is an edited version of the Tribunal's decision pursuant to s 60 of the South Australian Civil and Administrative Tribunal Act 2013. Some of the parties and participants of the proceedings have been de-identified in accordance with the Tribunal's anonymisation policy. Other facts and details that may lead to the identification of any person may have also been anonymised or omitted. These changes do not affect the Tribunal's decision or its reasons for decision.

1. On 19 July 2024 by Amended Initiating Application, the Nursing and Midwifery Board of Australia (Board), referred Sabrina Kay Bettridge (respondent) to the Tribunal pursuant to s 193 of the Health Practitioner Regulation National Law (National Law) being Schedule 2 to the Health Practitioner Regulation National Law (South Australia) Act 2010, on the grounds that the Board reasonably believes that the respondent has behaved in a way that constitutes professional misconduct.

1. The respondent who is currently aged 68, was conferred nursing qualifications by the Royal Adelaide Hospital in 1978 following which she registered with the South Australian Nursing Board on 5 March that same year.
2. Ms Bettridge was first registered pursuant to the National Law as a Registered Nurse (Division 1) on 1 July 2010. She allowed her registration to lapse on 2 July 2021 and has not sought re-registration since that date.
3. At all material times prior to 2 July 2021, as a Registered Nurse (Division 1), the respondent was subject to the provisions of the National Law and in particular, pursuant to s 39 the following relevant codes:
   • Code of Conduct for Nurses in Australia, effective from 1 March 2018 (Code of Conduct)
   • Registered Nurse Standards for Practice, effective from 1 June 2016 (Standards for Practice)
   • International Council for Nurses Code of Ethics for Nurses (Revised 2012 Edition), effective from 1 March 2018 (Code of Ethics).

1. There are two allegations made by the Board against the respondent, reproduced as follows:

Allegation 1-Failure to maintain professional boundaries in relation to a patient

(a) Professional misconduct within the meaning of paragraphs (a) and/or (c) of the definition of "professional misconduct "in s 5 of the National Law; and/or

(b) Unprofessional conduct as defined in s 5 of the National Law,

in that, between 21 August 2020 and 2 May 2021, she failed to maintain appropriate professional boundaries that should, and ordinarily do, delineate the relationship between a nurse and her patient by establishing an intimate personal relationship with a male patient (DNJ) during the time that DNJ was a patient under her professional care.

Allegation 2-Provision of false or misleading information to the Board during its investigation

(a) Professional misconduct within the meaning of paragraphs (a) and/or (c) of the definition of "professional misconduct" in s 5 of the National Law; and/or

(b) Unprofessional conduct as defined in s 5 of the national law,

in that, on 24 September 2021, she provided false or misleading information to the Board during its investigation of the conduct [the subject of Allegation 1].

1. The particulars of both allegations may be summarised as follows:
   • The respondent was employed as a support worker by two private care provider organisations between 29 September 2016 and 2 May 2021, providing in-house personal care to clients including a person referred to as DNJ. He was a client of both organisations at the material times of the alleged conduct.
   • DNJ suffered an acquired brain injury due to an assault in 2015. He has left-sided tetraplegia and a mental health diagnosis of bi-polar disorder.
   • On one occasion between 21 August 2020 and 2 May 2021, while the respondent was performing work duties at DNJ's home, DNJ was lying face down on his bed naked. The respondent rubbed cream onto his buttocks and anus without wearing gloves and without any apparent clinical justification.
   • On another occasion between 21 August 2020 and 2 May 2021, again whilst performing work duties, the respondent whilst assisting DNJ to get dressed, in response to DNJ attempting to pull down the front of her top, did pull down her top to expose her bra. DNJ reciprocated and grabbed one of her breasts. The respondent then hugged DNJ and fondled his penis and buttocks over his clothing.
   • Between 21 August 2020 and 2 May 2021, again whilst performing work duties in DNJ's bedroom, the respondent when DNJ was sitting on his bed wearing only a towel which he removed, rubbed cream into his buttocks, anus, penis and testicles. DNJ then squirted cream onto his penis and asked the respondent to rub it in. She did this with a masturbatory action. There was no clinical justification for any of the respondent's actions.
   • Between 24 November 2020 and 15 March 2021, the respondent and DNJ exchanged at least 590 text messages the context of which was personal and not relevant or necessary for DNJ's personal care. As a result of requests made by DNJ during these communications, the respondent purchased as a gift for him a hidden camera. This was provided on or about 10 December 2020, supposedly because DNJ believed that somebody who had access to his home was stealing marijuana from his bedroom. The respondent following further text message conversations, provided DNJ with further high-definition secret cameras on 18 December 2020 and on either 31 December 2020 or 1 January 2021. At all times, she either knew or ought to have known that DNJ wanted the cameras to secretly film the female care workers in his home whilst they were attending to his personal care needs either in his bedroom or bathroom.
   • Between 21 August 2020 and 2 May 2021, after becoming aware that DNJ had secretly filmed a fellow care worker with the use of one of the hidden cameras in his bathroom, the respondent failed to report DNJ's inappropriate conduct. She also failed to report his inappropriate conduct towards her between 21 August 2020 and 2 May 2021.
   • As a result of the fellow care worker reporting the abuse towards her, the South Australian Police (SAPOL) intervened and DNJ was arrested and charged in relation to the inappropriate use of the secret cameras installed in his home (with video recordings) and in relation to other illicit images on his phone and computer equipment. Accordingly, SAPOL became aware of the respondent's inappropriate behaviour including the text messaging between her and DNJ. SAPOL accordingly notified the Australian Health Practitioner Regulation Agency (AHPRA) on 25 June 2021.
   • On 24 September 2021, in response to the AHPRA notification, the respondent submitted correspondence through her former solicitor, that she was not aware that a disability care client had installed or was using cameras (in his home). She knew or ought to have known at that time, under the circumstances, that this was a false or misleading statement.

1. Ms Bettridge admits the alleged conduct as particularised with the exception of the following two discreet issues:
   • Her state of knowledge in relation to DNJ's intended use of the cameras which she provided to him.
   • The admissibility of her solicitor's letter of 24 September 2021, given that it was expressly marked as a "without prejudice" communication.
2. Accordingly, the matter proceeded to a Stage 1 hearing for the Tribunal to make findings about the factual conduct of the respondent and the characterisation of that conduct on 26 February 2025.

1. The Board tendered at the outset, the Tribunal Book (TB) [Exhibit A-1] containing the relevant documents including copies of the SMS text messages between DNJ and the respondent,[1] the letter of 24 September 2021,[2] Ms Bettridge's response to the allegations[3] , her affidavit dated 12 August 2024[4] and copies of the relevant professional Codes and Standards.[5]
2. The Board also tendered a Universal Serial Bus (USB) [Exhibit A-2] of the visual audio recordings of the incidents which form the subject of the first allegation.
3. As previously mentioned, the facts relating to the allegations are substantially agreed, save and except that in relation to Allegation 1, Ms Bettridge disputes that she specifically knew that DNJ wanted the covert cameras which she supplied so that he could film his female carers while they were attending to his personal care needs in his bedroom or while using his home toilet. She maintains that a camera was initially purchased because DNJ had told her that he was concerned about people accessing his home and stealing his marijuana which was secreted in his bedroom and that further cameras were purchased because DNJ complained about the poor quality of the first camera. The Tribunal notes however, the respondent does admit that she ought to have known that the camera(s) in DNJ's bedroom were being used inappropriately[6] (underlining added).
4. Whilst admitting the second allegation, the respondent (somewhat inconsistently) asserts that the letter sent by her lawyers (on her instructions) was 'without prejudice' correspondence, sent in circumstances where she (and her lawyers) had not been provided with any of the evidence by the Board and that they were attempting to resolve the matter without the Tribunal needing to become involved. Accordingly, the respondent submits that the Tribunal should not admit that letter into evidence (the only evidence upon which the Board relies to prove Allegation 2 ).[7] In the alternative, the respondent submits that if the letter is admitted, the Board would still need to prove that the statement made in the letter by the respondent's lawyer, namely "we are instructed that our client was not aware that a disability care client had installed or was using hidden cameras" was made for the purpose of misleading the Board.[8]
5. Prior to the Stage 1 hearing, the Tribunal was provided with written submissions by the Board and the respondent. Those submissions were supplemented by the oral submissions of Mr Hurburgh the Board's Counsel. Mr Edwards, Counsel for the respondent chose to rely on the written submissions which were prepared and provided by his client's previous legal representatives. At the conclusion of the hearing, taking into account the submissions and the evidence, the Tribunal made the following findings:

• That between 21 August 2020 and 2 May 2021, the respondent, while at work, engaged on three occasions in inappropriate contact with DNJ (as set out in paragraphs 3.6, 3.7 & 3.8 of the amended initiating application) without clinical justification.[9]
• That between 24 November 2020 and 15 March 2021, the respondent exchanged with DNJ a significant number of SMS/text messages-in the order of 590 (as described in paragraph 3.9 of the amended initiating application).[10]
• On or about 1 December 2020, the respondent purchased a hidden camera as a gift, at the request of DNJ on 29 November 2020. She subsequently provided him with two further cameras of better quality.
• That the respondent knew or ought to have known that DNJ wanted a hidden camera so that he could record his female workers while they were attending to his personal care needs in his bedroom (as alleged in paragraph 3.11 of the amended initiating application).[11] The Tribunal is not satisfied that the respondent knew that any camera was to be used by DNJ in his toilet.
• That between 21 August 2020 and 2 May 2021, the respondent failed to report inappropriate conduct towards her and at least one other personal support worker (as described in paragraph 3.12 of the amended initiating application).[12]

• That on 24 September 2021, the respondent provided false and misleading information to the Board during its investigation in a written response through her solicitors in which she stated that she was not aware that a disability care client had installed or was using hidden cameras. The Tribunal accepts that the correspondence is admissible as evidence not as the truth or falsity of the statement, but the fact that the statement was made to the Board on behalf of the respondent and she now accepts that it is a false statement.

1. In coming to our findings on the evidence, we are satisfied on the balance of probabilities, taking into account the Briginshaw principle given the very serious nature of the allegations and the consequences that will impact on the respondent.[13]
2. The reasons for the Tribunal's findings may be summarised as follows:

• DNJ has a well-documented acquired brain injury due to an assault in 2015 and left-sided tetraplegia. He also has an established diagnosis of bipolar disorder. His brain injury causes behavioural issues which make him susceptible to outbursts of anger, frustration and agitation. It was recorded on work plans and reports which would have been made available to the respondent by her employers or ought to have been known by her, that DNJ displayed "sexual tendencies normally during personal care shifts".[14]
• The respondent in the course of her employment, provided DNJ with personal care within his home each workday for two hours per day.[15]
• The text messages exchanged between the respondent and DNJ were clearly of a personal and professionally inappropriate nature.[16]
• The USB evidence [Exhibit A-2] graphically visually depicts the respondent on three separate occasions (as alleged between 21 August 2020 and 2 May 2021):
  • rubbing cream into DNJ's buttocks, anus, penis and testicles and rubbing/stroking his penis in a masturbatory fashion;
  • fondling DNJ's penis and buttocks over his clothing; and
  • pulling down her top to expose her bra and DNJ then grabbing her breasts. There cannot be any justification for any such contact (clinical or otherwise).
• The respondent does not dispute that she purchased one hidden camera for DNJ which she gave to him as a birthday gift on 10 December 2020 and that she then provided him with two further cameras on 18 December 2020 and either 31 December 2020 or 1 January 2021.
• In relation to the intended use of the cameras, we note that the following audio recorded conversation between the respondent and DNJ at the time that she inappropriately touched his penis, testicles, buttocks and anus:

Respondent: What you've got the camera on? > > [DNJ]: It's always pretty well on > > Respondent: [laughter] of course, of course...

Ms Bettridge goes on to say while rubbing DNJ's penis with her hand "listen, look, you'd better not have this bloody camera rolling", before commenting after rubbing his penis, "right, okay, you're perfect".

That incident took place in DNJ's bedroom, the room in which he kept his marijuana, which in the text messages between the respondent and DNJ he had stated that he wished to install a hidden camera as a means of protecting that supply. There can be no doubt from both the recorded audio conversations and the text messages that the respondent knew when she purchased and supplied the cameras to DNJ, that he intended to install them in his bedroom and that he was recording the actions of his personal carers, including her.

• There was text messages exchanged which referred to DNJ's intention to use hidden cameras to record his personal care workers attending to his needs.
• In regard to the hidden camera in the toilet/bathroom however, there is no such evidence that would comfortably satisfy us that the respondent knew for a fact or on our assessment, ought to have known that DNJ had secreted a camera in that room at the time of the purchase and supply of any of the cameras.
• It was not until sometime later, that the respondent became aware of the incident concerning the filming of another care worker in the toilet of DNJ's home, the incident which led to the involvement of SAPOL and the subsequent notification to AHPRA.
• After her behaviour came to light, when spoken to by the General Manager of her employer, the respondent stated that DNJ was attractive and that he had a big penis.[17]
• We note the respondent agrees that she did not notify the relevant authorities (including her employer) both of the inappropriate behaviour of DNJ towards her or her fellow worker.

• The Tribunal notes that the respondent agrees that the statement contained in her lawyer's letter dated 24 September 2021 (previously referred to) is false.
• The Board asserts that the statement was made in order to mislead the Board into believing that it was true.
• The respondent submits that the assertion was made "without prejudice" at a time when she and her solicitor had not been provided with the evidence now relied on by the Board, and in circumstances where she was attempting to resolve the matter without the Tribunal's involvement.
• The Tribunal has been referred to a number of legal authorities on this point and in particular, Davies v Nyland[18] where at [89-90], it was held that "without prejudice" correspondence is not determinative of whether it should attract the privilege of excluding correspondence into evidence, as proof of offending conduct.
• We are satisfied that at the time the respondent's former solicitors corresponded with the Board in response to the initial complaint, proceedings were not at a stage of genuine negotiation and accordingly, the common law privilege to protect admissions in an attempt to resolve a dispute, would not apply.
• We consider that the correspondence of 24 September 2021 is therefore admissible as evidence and we note that the respondent acknowledges that the statement that she was not aware that a disability care client had installed or was using hidden cameras is false, as confirmed by the evidence before us.
• Before departing from this topic, we wish to say something about the affidavit evidence of the respondent. Ms Bettridge affirmed that affidavit on 12 August 2024. In that document, she acknowledges that she ought to have known that DNJ wanted a hidden camera so he could film female workers while they were attending to his personal care needs in his bedroom. She goes on to say, "I disagree that I positively knew that this is what the cameras were for".[19]
• The respondent states further that she agrees with Allegation 2 "as I do not wish to proceed to a full hearing in the matter"[20] but then goes on to state, "whilst I accept that I knew of the cameras, I did not know that the cameras were being used in the way they were".[21]
• The respondent elected during these proceedings to not subject herself to cross-examination (which is her right). However, as a result, the Tribunal has been deprived of the opportunity to appropriately assess the veracity of her assertions and her credibility and demeanour as a witness, such that we cannot place much weight on her affidavit evidence. Indeed, her assertions of the facts in that document, can accurately be described as self-serving statements, which we reject.

1. The Tribunal must objectively assess the extent to which the respondent's conduct as found, departs from the proper professional standards of the Nursing and Midwifery profession.[22]
2. Taking into account the definition of professional misconduct as set out in s 5 of the National Law and having regard to the Board's Code of Conduct, Code of Ethics and Standards for Practice (as admissible under s 41), we are well satisfied that the respondent's conduct, regarding both allegations (as found), amounts to professional misconduct. That is, conduct substantially below the standard reasonably expected of a registered health practitioner of an equivalent level of training or experience as Ms Bettridge.
3. On account of her conduct, we find that the respondent is not a fit and proper person to practise the profession of a registered nurse or other health carer. We do note that notwithstanding our findings, the respondent in any event, admits that she has engaged in professional misconduct regarding Allegation 1.[23]

1. We turn now to the issue of sanctions. Counsel for both parties provided the Tribunal with written outlines of submissions prior to the hearing on 25 March 2025.

The Board submits that in light of the Tribunal's findings, that the respondent should be:

• Reprimanded;
• Disqualified from applying for registration as a health practitioner for a period of eight years; and
• Prohibited from providing any health service until such time as registered as a health practitioner.

• The Tribunal's findings must be recognised, including that her knowledge was limited to DNJ's recording of other carers in his bedroom (only);
• She has made admissions and concessions about most factual matters which demonstrate a level of cooperation for which she should be given credit;
• It is relevant that she has a lack of disciplinary history, that she allowed her registration to lapse in July 2021 and has not sought re-registration since; and
• A disqualification and prohibition for a period of eight years are very severe sanctions warranted in matters involving extremely severe exploitation and proportionately severe harm which can be distinguished from the facts as found in this matter.

1. It should be acknowledged that in her affidavit, Ms Bettridge has referred to a number of personal stressors which were intervening in her life during the relevant period including a strained relationship with her husband, personal trauma affecting her son, workload issues and declining mental health resulting in a recent diagnosis of post-traumatic stress disorder.[24]

1. The starting point in considering any sanction for professional misconduct is always that the purpose of disciplinary proceedings is principally the protection of the public and that there is no element of punishing the practitioner concerned.[25] In the well cited case of Craig v Medical Board of South Australia[26] at [553-555], the former Chief Justice Doyle set out succinctly the other important purposes of sanctioning proceedings which were recently canvassed in Pharmacy Board of Australia v Roberts[27] and may be summarised accordingly:

The imposition of disciplinary sanction may serve one or all of the following purposes-

(a) preventing practitioners who are unfit to practise from doing so;

(b) securing the maintenance of professional standards;

(c) assuring members of the public and the relevant profession that appropriate standards are being maintained and that professional misconduct will not be tolerated;

(d) bringing home to a practitioner the seriousness of their conduct;

(e) deterring a practitioner from any future departures from appropriate standards;

(f) deterring other members of the profession who might be minded to act in a similar way;

(g) imposing restrictions on a practitioner's right to practise so as to ensure that the public is protected.

1. It is important to note that sometimes the protection of the public requires disciplinary action which has a greater adverse effect on the practitioner than may be warranted if punishment was the relevant consideration[28] and that the personal circumstances of a practitioner may be of limited significance in the process of determining what sanctions are necessary in the public interest.[29]

1. Ms Bettridge's inappropriate physical contact with DNJ involved contact with his penis, buttocks, anus and testicles (without surgical gloves) under the guise of providing personal care services, on three separate occasions all without clinical justification. This was in relation to a vulnerable person who was known by the care services organisations employing the respondent to display sexual disinhibition as a feature of his acquired brain injury-a fact documented and at the relevant times either known by the respondent or ought to have been known by her.[30] The respondent knew or at the very least ought to have known that DNJ wanted covert cameras to film his carers in his bedroom and that he would have received sexual gratification from watching those recordings.
2. Apart from the inappropriate physical touching and provision of cameras, there are the clearly inappropriate text messages which demonstrate a crossing of professional boundaries as well as a failure to report not only DNJ's inappropriate conduct towards the respondent, but also her failure to report his inappropriate conduct in filming other care workers as they were attending to his care needs. The respondent's conduct in all of these matters in itself would be sufficient to amount to professional misconduct in our view. However, to compound the situation, there is the further conduct of misleading the Board in its investigations as we have found.
3. We consider that the respondent has demonstrated a low level of insight into her misconduct. Her admissions were not made at the earliest opportunity but only after the Board had gathered and produced substantial evidence to support the allegations. Even then, she did not make full admissions but rather elected to put the Board to proof both in relation to her knowledge about why DNJ wanted the covert cameras and regarding her intention to mislead the Board and AHPRA in the investigations of the complaints.
4. Whilst we do accept that Ms Bettridge was suffering some personal stressors and mental health issues during the period of her conduct as previously referred to, we do not find that these form a basis to either explain her conduct or a demonstration of remorse. Indeed at no stage of these proceedings (even after our factual findings) has the respondent apologised either to DNJ, AHPRA or her profession at large for her conduct.
5. The wider public, the Nursing and Midwifery profession and consumer groups charged with the responsibility of protecting and advocating for the rights of vulnerable persons requiring care assistance, have every right to be outraged by the respondent's deplorable conduct. She was employed to attend to a client's care in his own home but instead, chose to unashamedly engage in conduct which was clearly also for her own sexual gratification.
6. In assessing what are appropriate sanctions here, we must consider the paramount need to protect the public, as well as the ancillary needs to send a very strong message to the Nursing and Midwifery profession that such conduct will not be tolerated and that in the interests of general deterrence, those members of the profession who engage in such conduct will face substantial consequences. We must also consider the need to deter Ms Bettridge herself from engaging in such conduct in the future, notwithstanding the fact that she has retired from the profession and has not sought re-registration since 2021. It is incumbent on us to have regard to the risk of the respondent engaging in misconduct again, even though she comes before the Tribunal without any prior disciplinary history.
7. There can be no doubt that it is appropriate to disqualify the respondent from applying for registration and to prohibit her from working in the health industry in any capacity in accordance with the observations of Chief Justice Kourakis in Marin v Chiropractic Board of Australia[31] "to strengthen disqualification orders by prohibiting a disqualified health professional from providing any of those other services".[32]
8. The Board suggests a disqualification period of eight years is justified given the seriousness of the respondent's conduct and has referred the Tribunal to the case of Nursing and Midwifery Board of Australia v Farrow[33] where the practitioner had installed surveillance devices in female toilets and change rooms at his place of work and engaged in other sexualised misconduct towards both patients and professional colleagues. In that matter, Mr Farrow was disqualified from applying for registration for a period of ten years. The respondent submits that Farrow is a much more serious matter to the one here and that accordingly, a disqualification and prohibition of eight years as proposed by the Board is excessive. The respondent submits that such terms should be reserved for matters involving extremely severe exploitation and 'almost inevitably proportionately severe harm".[34] We accept that submission.
9. On the basis of all the evidence and the submissions before us, we consider the following sanctions are appropriate. Accordingly, orders under the National Law will be made as follows:

(a) The respondent is reprimanded.

(b) The respondent is disqualified from applying for registration as a registered health practitioner for a period of six years from the date of this order.

(c) The respondent is prohibited from providing health services in any capacity, whether paid, or unpaid in any care facility or private home during the period of disqualification and until such time as she is registered as a health practitioner.

(d) The respondent is to pay the Board's reasonable costs as agreed or in default of agreement, as set by the Tribunal.

1. Finally, we wish to state that we trust that the sanctions we have imposed will sufficiently denounce the respondent's professional misconduct and emphasise the Tribunal's disapproval of it by signalling that those whose conduct does not meet the required standards will not be permitted to practise. This is to ensure that public confidence in the Nursing and Midwifery profession is maintained, especially regarding the provision of in-home care services for the vulnerable members of our community.

[7] TB P 463 [12] and respondent's outline of argument 3 October 2025.

[13] Briginshaw v Briginshaw [1938] HCA 34; (1938) 60 CLR 336.

[18] (1974) SASR 76.

[19] Respondent's affidavit 12 August 2024 at [8].

[22] Health Care Complaints Commission v Litchfield (1997) 41 NSWLR 630, at 637E.

[23] Respondent's affidavit, ibid [6] and TB, P 462.

[24] Respondent's affidavit 12 August 2024 at [27-80].

[25] Bar Association (NSW) v Evatt [1968] HCA 20; (1968) 117 CLR 177.

[26] [2001] SASC 169; (2001) 79 SASR 545.

[27] [2022] SACAT 111.

[28] Craig v Medical Board of South Australia, ibid at [43].

[29] Health Care Complaints Commission & Litchfield (1997) 41 NSWLR 630, at 637F.

[31] [2020] SASCFC 74.

[33] [2022] VCAT 43.

[34] Respondent's outline of submissions on sanction, 21 March 2025 at [15].