A NSW paramedic has had his registration cancelled for not less than two years after he was convicted of several domestic violence offences and after he failed to report that he had been charged, and then convicted, as required by the Health Practitioner Regulation National Law (Health Care Complaints Commission v Bah [2026] NSWCATOD 139). The Health Care Complaints Commission (the HCCC) said ([2]):

This matter is about a paramedic who drank alcohol then physically assaulted his partner on three occasions, who has been charged and convicted of domestic violence offences, who failed to notify the National Board of his charges and convictions and who has an impairment, severe alcohol use disorder.

In March 2024 Mr Bah was convicted of offences relating to breach of an apprehended violence order (x 2), causing grievous bodily harm and assault (x 2) – all related to domestic violence, and hinder/resist police. There were other charges that it appears he was not convicted of but, in any event, it was alleged that he failed to comply with the National Law when he failed to report both that he was charged with various offences and when he was ultimately convicted of the offences listed above.  It was also alleged that his alcohol use disorder constituted an impairment ‘that detrimentally affects or is likely to detrimentally affect the practitioner’s capacity to practice (sic) the profession of Paramedic’ ([14]).

Mr Bah’s legal troubles with alcohol began in 2020 when he was charged with driving with the high range prescribed concentration of alcohol ([17]). Over the next years he had ‘difficult, unpleasant, and uncooperative’ interactions with police, was detained under the Mental Health Act for assessment, and ‘was admitted to Liverpool Fairfield Aged and Mental Health Care unit because of concerns about his mental state and his “D&A use” ([24]-[26]).  Throughout this time he was supported by his employer, NSW Ambulance, at [22] the Tribunal said:

The Ambulance Service has remained very supportive of Mr Bah – he acknowledged on 20 April 2021 that “he had been very well supported by [it] throughout this very difficult time and he was going to change”. The Service’s on-going support of the troubled employee was exemplary.

He was ultimately dismissed by the Ambulance Service on 8 July 2025

Mr Bah did not take part in the proceedings but the Tribunal appreciated the balanced way the HCCC presented the case. The Tribunal referred to (at [12]) ‘… the HCCC’s balanced approach in the presentation of its evidence – the Commission placed before us substantial material favourable to Mr Bah’.

At [60]-[70] the Tribunal said:

… we find Mr Bah “unfit in the public interest to practise paramedicine”, as a consequence of the circumstances and gravity of his repeated offences, and his consequential convictions, and the lengthy time period over which they occurred.

His behaviour has been completely unacceptable, and “he cannot be trusted to comply with court [or Tribunal] orders… and maintain high ethical standards”. We are entirely satisfied that Mr Bah’s registration should be cancelled.

Secondly, the HCCC asks the Tribunal to impose, in its discretion, a two-year non-review period, under s 149C(7) of the National Law.

Again, the paramount consideration for us must be to the health and safety of the public.

Given the length of time that Mr Bah has continued his drinking and dangerous behaviour, we are satisfied that he will need at least two years to accomplish a concerted change of approach, and to implement the programme Dr Dore has spelled out for him.

Accordingly, we will make a non-review order, as sought.

Thirdly, we are asked to make a prohibition order, under s 149C(5) of the National Law.

We are entirely satisfied, in terms of that provision, that Mr Bah “poses a substantial risk to the health of members of the public”, if he were to be involved in the provision of health services…

His conduct shows a tendency to become violent when stressed, or drinking alcohol, and Dr Dore opines that a comprehensive treatment regime is called for. While there is great sadness in this case, and it is unfortunate that Mr Bah did not participate in these proceedings, it would appear to us that Mr Bah has developed no insight at all into his behaviour and the serious problems he has caused to himself and others.

As the HCCC submits, “it would be incompatible with the Tribunal’s obligation to protect the public to allow the practitioner to provide unregistered health services to members of the public”, and “would substantially undermine the protective purpose of [our] cancellation order”: Health Care Complaints Commission v Shrimpton (No 2)[2019] NSWCATOD 48 at [25].

Accordingly, we are prepared to make a prohibition order, as requested.

Mr Bah was also ordered to pay the HCCC’s costs.

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