regulatory

Physician and Anaesthesia Associates: Delegation, Informed Consent, and Montgomery in the Administrative Court

26 September 2025 by Guest Contributor

By Kian Leong Tan

INTRODUCTION

In R (Anaesthetists United Ltd and Others) v General Medical Council [2025] EWHC 2270 (Admin) (“Anaesthetists United”), Mrs Justice Lambert dismissed a judicial review claim brought by the claimants against the defendant regulator for Physician Associates (“PAs”) and Anaesthesia Associates (“AAs”) – collectively referred to hereafter as “Associates” – in the UK.

The claim is the most recent instalment in a brewing saga over the continued use and regulation of Associates in the UK’s healthcare system:

• In April 2025, Lambert J dismissed the British Medical Association (“BMA”)’s judicial review challenge (R (British Medical Association v General Medical Council [2025] EWHC 960 (Admin)) to the GMC’s decisions to (i) apply the same basic professional standards to doctors and Associates, and (ii) refer to all three professions collectively as ‘medical professionals’.
• Just prior to the handing down of Anaesthetists United, Professor Gillian Leng released her final report following the conclusion of her independent review into the Associate professions.