Application for dismissal of a disciplinary case of the Institute and Faculty of Actuaries
This case concerns the freedom of speech of professionals who are subject to regulation and discipline by professional bodies. Patrick Lee (PL), an actuary, is undergoing a disciplinary process by his (former) professional body the Institute and Faculty of Actuaries (IFoA) following tweets/retweets he made criticising the Islamic religion.
Following complaints during and after his membership, IFoA alleged his tweets and retweets used inflammatory language or language designed to offend Muslims. PL has resigned from the IFoA by not renewing his membership.
The disciplinary tribunal on 9 May 2023 considered PL’s application for dismissal on the basis that the panel is acting ultra vires, beyond the powers given by the Royal Charter, byelaws, and rules. PL’s barrister argued that the disciplinary proceedings on the allegation, served after PL’s membership ceased, and the second allegation made after PL had left membership were not valid.
The panel disagreed and dismissed the application. We will post their written decision here when issued. The disciplinary hearing is scheduled for December.
We reported his 2nd application for a judicial review (JR) of the IFoA disciplinary process here https://tribunaltweets.substack.com/p/application-for-judicial-review-patrick
Live tweet threads
Abbreviations
Institute and Faculty of Actuaries: IFoA
Disciplinary Tribunal Panel: DTP
Panel members:
Peter Wrench (lay member of panel and Panel Chair): PW or C for chair
Paul Rae (lay member of panel): PR
Simon Head FIA (Fellow of the Institute of Actuaries, actuary panel member): SH
Sharmistha Michaels (barrister, legal adviser to IFoA DTPl): SM
Rachna Gokani (Counsel for the IFoA): RG
Nicholas Leviseur (Counsel for Patrick Lee): NL
Patrick Lee (Respondent): PL
Respondent : R
Witness statement: WS