Suspension under Regulation 23A and administrative delay: proportionality review reduces active suspension to period already served

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....Proportionality of an administrative penalty was contested following prolonged disciplinary proceedings that triggered an automatic suspension of authorisation. The reasoning emphasises that excessive delay between showcause notice and final order produced cumulative prejudice, making the original twoyear suspension disproportionate. The disciplinary committee failed to account for the period already endured; consequently, the active suspension was reduced to time already served and deemed ended from the date of the order. The decision therefore mitigates penalty based on delay, cumulative effect, and failure to consider mitigating factors.....