Panel Consideration Meeting - Conduct - Neil McLaren

Definitions

Any reference in this outcome to:

• ‘GTC Scotland’ means the General Teaching Council for Scotland;
• the ‘Panel’ means the Fitness to Teach Panel considering the case;
• the ‘Rules’ (and any related expression) means the GTC Scotland Fitness to Teach Rules 2017 or refers to a provision (or provisions) within them;
• the ‘Register’ means the GTC Scotland Register of teachers; and
• ‘COPAC’ means the GTC Scotland Code of Professionalism and Conduct.

Notification of Meeting

The Panel had before it a copy of the Notice of Panel Consideration, dated 20 April 2026. The Panel was satisfied that the Applicant had been provided with notice of the meeting in accordance with Rules 1.6 and 2.3.1.

Accordingly, the Panel proceeded to consider the case.

Preliminary Matters

No preliminary matters were raised.

Allegation(s)

1. On 7 October 2022 the Applicant was convicted of the following offence at Dundee Sheriff Court:
   
   • (a) On an occasion in April 2022 and June 2022, at [redacted] and elsewhere unknown to the Procurator Fiscal you [Applicant] did behave in a threatening and abusive manner likely to cause a reasonable person to suffer fear and alarm and you did cause your partner or ex-partner [redacted] c/o Police Service of Scotland, fear and did strike her vehicle and utter threats of violence towards her and her new partner; Contrary to Section 38(1) Criminal Justice and Licensing (Scotland) Act 2010 and it will be proved in terms of Section 1 of the Abusive Behaviour and Sexual Harm (Scotland) Act 2016 that the aforesaid offence was aggravated by involving abuse of your partner or ex-partner.

And in respect of this conviction, on 4 April 2023, the court admonished and dismissed the Applicant.

In light of the alleged conduct the Applicant’s fitness to teach is impaired and/or he is unfit to teach as a result of breaching Parts 1.3, 1.4 and 1.6 of GTC Scotland’s Code of Professionalism and Conduct 2012.

Information Available to the Panel

1. Final Investigation Report, dated 16 April 2026, with appendices including:
2. Notification of Investigation Response Form, dated 24 February 2026
3. PVG Scheme Disclosure, dated 9 February 2026
4. Extract conviction, dated 8 April 2026

In response to the notice, the Applicant provided the following additional information for consideration by the Panel:

1. Response from Applicant, dated 8 May 2026, with appendices including:
   
   • Patient Summary Sheet, undated
   • Summative Assessment Form 1, dated 2 March 2026
   • Summative Assessment Form 2, dated 11 March 2026
   • Summative Assessment Form 3, dated 6 May 2026
   • Reference, undated

Applicant’s Response

The Applicant accepts his conviction and, in his response, does not seek to minimise or excuse his behaviour. The applicant’s position is that his fitness to teach is not currently impaired. Since his conviction he has sought appropriate treatment for [redacted] and his personal circumstances have changed. His position is that he is fit to teach and that there will be no recurrence of his behaviour which arose from a particular set of personal circumstances and [redacted].

Summary of Evidence and Submissions

The Panel noted that it had before it, evidence of the Applicant’s conviction and his responses to the GTC Scotland investigation. The Panel noted the Applicant's admission of the allegations and his position on them.

It had regard to the GTC Scotland Panel Consideration Practice Statement and to the GTC Scotland Fitness to Teach Conduct Cases – Indicative Outcomes Guidance Practice Statement (‘IOG’ Practice Statement) in making its decision.

Decision

The Panel considered all the information available to it as described above. The Panel had a range of options open to it, as set out at Rule 2.3.2 (a) to (f). The Panel had regard to the factors set out in the GTC Scotland Panel Consideration Practice Statement.

The Panel did not consider it appropriate to dispose of the case in accordance with Rule 2.3.2 (a). The Panel reached this conclusion for the following reasons:

The matter amounts to Relevant Conduct and there is on the face of it, a real prospect of a finding that the Applicant’s fitness to teach is impaired. The Panel considered the following factors relevant in that the conduct alleged relates to:

• Behaviour of a violent, aggressive or threatening nature

The Panel considered the relevant Parts of COPAC to be:

1.3 you should avoid situations both within and out with the professional context which could be in breach of the criminal law, or may call into question your fitness to teach;

Given that this matter stems from a criminal conviction it was clear to the Panel that part 1.3 of COPAC 2012 was engaged.

1.4 you must uphold standards of personal and professional conduct, honesty and integrity so that the public have confidence in you as a teacher and teaching as a profession;

Again, the circumstances of the criminal conviction led the Panel to the view that part 1.4 was engaged.

1.6 you should maintain an awareness that as a teacher you are a role model to pupils

The Panel was also clear that a criminal conviction in relation to violent, aggressive and threatening behaviour was not the appropriate behaviour to model for pupils and that therefore part 1.6 was engaged.

The Panel considered the following additional factors to be relevant in their decision:

• The matter is not over 5 years of age with the criminal conviction dating from 2022.
• The matter has not already been considered.
• The matter is not frivolous or vexatious. It involves a conviction for conduct which was threatening and aggressive and cannot be said to be frivolous or vexatious.
• The allegations have not been made anonymously or by a person who has failed to cooperate with the investigation.

The Panel did not consider it appropriate to dismiss the case based on an insufficiency of evidence as provided for by Rule 2.3.2 (b). The allegations have been admitted by the Applicant.

Furthermore, the Panel did not consider the referral to be malicious.

The Panel had regard to Rule 1.7.18:

‘Subject to rule 1.7.19, where a teacher has been convicted of a criminal offence (and provided that such conviction is neither pending appeal nor been successfully appealed):

(a) an extract conviction, or copy of the certificate of conviction certified by a competent officer of the relevant court, will be conclusive proof of the conviction; and

(b) any findings of fact upon which the conviction is based will be admissible as evidence of those facts'

Fitness to Teach

The Panel carefully considered all the available information and had regard to Stage 2 of the GTC Scotland Fitness to Teach Conduct Cases – Indicative Outcomes Guidance Practice Statement (‘IOG’ Practice Statement) in considering whether the Applicant’s fitness to teach is currently impaired.

Firstly, the Panel required to reach a decision on whether the facts found proved mean that the Applicant’s conduct at that time fell short of the expected professional standards.

The Panel, for all the reasons set out above and with reference to the COPAC 2012 breaches identified were satisfied that the Applicant’s conduct at the time of the allegations had fallen short of the required standard.

The Panel then were required to consider whether the shortfalls identified in the applicant's conduct were:

a) remediable and;

b) have they been remedied by the Applicant and;

c) what is the risk of reoccurrence?

The panel also considered the public interest in this matter.

The Panel sought legal advice regarding the disposal of the criminal matter by the Sheriff Court, The Panel was advised that the Applicant was admonished; meaning that the Sheriff imposed the lowest penalty available to the court. An admonishment also means that the conviction is immediately treated as being ‘spent’ in terms of the Rehabilitation of Offenders Act 1974.

The Panel also took into account the applicant’s position on the circumstances surrounding the offence. The offence was committed approximately four years ago and seemed on the Panel’s reading to have come against the background of a ‘perfect storm’ of circumstances. Since then, there had been context provided and there was mitigation which must have been accepted by the criminal court given the disposal.

The Panel also noted the Applicant's position that he did not seek to excuse or minimise his behaviour, which he acknowledged was serious but that it was against the background of a very specific set of personal circumstances. The complainer in the criminal matter was his former partner with whom his relationship had recently ended acrimoniously. He was also at that time being assessed for [redacted]. The Panel noted that the Applicant had appropriate support and coping strategies in place to manage [redaction] and to ensure there is no repetition. In addition, the Panel noted his submission that since the conviction he had become a father and that this had also altered his perspective and personal circumstances to make recurrence unlikely.

The Panel accepted that he had taken steps to reflect on his actions and on his response to the situation he found himself in and that his response showed evidence of remorse and insight into his behaviour. The Panel also accepted his clear and cogent outlining of the practical support he had sought. The Panel was impressed with his being pro-active in managing his [redacted].

The Panel noted the protective factors in place with the Applicant now being a father and beginning a new career in teaching which appeared to motivate him to make sure there was no recurrence.

The Panel also considered the wider public interest in reaching its decision. The panel considered that the behaviour the Applicant had displayed was in a very specific context and that there were no potential issues around protection of the public. The Panel also concluded that the maintenance of the public’s confidence in teachers and in the integrity of the teaching profession and also the maintenance of the public’s confidence in GTC Scotland as a professional regulator was satisfied by the fact that it had engaged in a thorough process of investigation and assessment of the applicant’s fitness to teach. The Applicant had also engaged fully with that process.

For these reasons and after careful consideration, the Panel concluded that the Applicant’s fitness to teach is not currently impaired and in accordance with Rule 2.3.2 (d) it directed that no further action be taken.