A dentist who was struck off after making a series of ‘racially motivated’ disparaging comments about ‘Indian dentists’ has won her High Court fight to be reinstated.
Southampton-based Hanna Grzelczak, 48, who qualified as a dentist in Poland in 2003 before moving to the UK in 2009, sent a series of emails to staff at the Damira Dental Studios, in Fareham, Hampshire, asking for online links connecting her with the firm to be removed.
The High Court heard that Ms Grzelczak began working for Damira in January 2022, initially in a locum position and then permanently as an associate dentist from May 2022.
Eleven months later, on March 28, 2023, Ms Grzelczak gave notice of her resignation, effective June 30, 2023.
From late July 2023, Ms Grzelczak wrote to the practice asking for her name to be removed from its website and online materials, making remarks relating to ‘Indian’ dentistry in four emails.
A complaint was raised with the General Dental Council and, following an investigation, Ms Grzelczak was struck off – but this has now been overturned and replaced with a six-month suspension.
Ms Grzelczak told staff in one email: ‘I am buying private practice. I noticed my name Hanna Grzelczak dentist In Google is connected with Damira practices.
‘I feel low with this connection as Damira is NHS low quality service and this is Indian company! It is a shame to me.
Southampton-based Hanna Grzelczak, 48, who qualified as a dentist in Poland in 2003 before moving to the UK in 2009, sent a series of emails to staff at the Damira Dental Studios, in Fareham, Hampshire, making references to ‘Indian dentistry’
‘I don’t want to be connected with Indian dentistry. I am not Indian. Please remember I don’t provide Indian implants… I provide German technology.’
A complaint was filed and four allegations were brought before a fitness to practise panel, each relating to one of the emails.
It was alleged that the communications were ‘unprofessional, inappropriate and racially motivated’ and that Ms Grzelczak’s fitness to practise was impaired due to misconduct.
At the start of the committee hearing on 22 September 2025, Ms Grzelczak formally admitted all the allegations.
After the three-day hearing, the General Dental Council’s (GDC) Professional Conduct Committee erased her name from the register following findings of misconduct and impairment.
But she has now won a High Court fight to be reinstated after a judge found that, whilst her comments had been ‘racially motivated,’ her attitude was not so ‘entrenched or irremediable’ as to necessitate her never being allowed to work as a UK dentist again.
Giving reasons for striking her off, the GDC panel told Ms Grzelczak: ‘You have breached a fundamental tenet of the profession, namely the need to treat others with respect and not bring the profession into disrepute.
‘The misconduct that the committee has found, relating as it does to racially-motivated comments, connotes a deep-seated and harmful personality or professional attitudinal issue.
The High Court heard that Ms Grzelczak began working for Damira in January 2022, initially in a locum position and then permanently as an associate dentist from May 2022
‘You have not engaged properly with the nature of your misconduct, in that you have sought to downplay your culpability by referring to your comments as, for instance, “illogical”, “nonsense” and “silly”.
‘In the committee’s judgment, you have not demonstrated that you fully understand just how offensive your comments were.’
She went on to mount a High Court challenge, asking Judge Bilal Siddique to reverse the GDC decision to strike her off.
The judge said she had admitted that she used ‘irrational, racist words to express my frustration and reach my objectives’, adding: ‘On the evidence, I find that Ms Grzelczak lashed out in anger, using racist comments because she knew they would be hurtful.’
But he went on to say that she should not have been struck off, adding that ‘erasure is reserved for behaviour fundamentally incompatible with continued registration, such as an attitudinal concern that is entrenched or irremediable.
‘I accept that Ms Grzelczak’s misconduct represented a serious departure from the professional standards expected of a registered dentist, particularly the duties to treat colleagues with respect, to avoid discriminatory behaviour, and not to bring the profession into disrepute.
‘However, Ms Grzelczak admitted the allegations in full at the outset of the hearing, accepted that her conduct amounted to misconduct, and accepted that her fitness to practise was impaired.
‘Although at times her explanations were inadequate and revealed attempts to minimise or rationalise her conduct, they do not demonstrate an entrenched or enduring refusal to acknowledge wrongdoing.
‘In my judgment, this evidence falls materially short of establishing the kind of sustained, deep-seated attitudinal defect or persistent lack of insight that would render erasure the only proportionate sanction.
‘My own assessment of Ms Grzelczak’s emails is that whilst they were plainly offensive, inappropriate and racially motivated, they do not approach the level of conduct that would give rise to a risk of serious harm of the kind contemplated in the sanctions guidance for a sanction of erasure.
‘The emails did not involve patients, nor give rise to any immediate risk to patient safety, clinical care, or the physical or psychological wellbeing of others. Whilst they had the potential to cause some distress and harm, their gravity lies in their unprofessional and racially motivated nature rather than in any potential to cause serious harm.
‘The threshold for erasure is met only where the misconduct has caused serious harm or presents a continuing risk of serious harm, or where the behaviour is so fundamentally incompatible with continued registration that no lesser sanction will suffice.
‘That would include, for example, cases where the attitudinal concern is entrenched or irremediable. This is not such a case.
‘Accordingly, the appeal is allowed. I therefore substitute the sanction of erasure with a direction that Ms Grzelczak’s registration be suspended for a period of six months.’
