In Doyle v. College of Physicians and Surgeons of Ontario, Ontario’s medical discipline tribunal decided that a psychiatrist whose licence had been revoked could return to practice — but only under strict rules designed to protect patients
Dr. Christopher Doyle lost his medical licence in 2018 after the College of Physicians and Surgeons of Ontario found serious problems with his conduct over many years, including:
Crossing professional boundaries with patients
Poor judgment in dealing with vulnerable individuals
Inadequate medical records
Improper handling of patient care and termination of treatment
A pattern of concerns despite years of supervision and therapy
In one case, a vulnerable patient experienced severe emotional distress and was hospitalized after the doctor ended care in an inappropriate way. The discipline panel concluded at the time that patients were not safe, even if restrictions were put in place.
Yes — but it is not automatic and happens only in rare cases.
Under Ontario law, a doctor whose licence has been revoked (except for certain sexual abuse findings) may apply for reinstatement after at least one year. The doctor must prove that allowing them back into practice is safe for patients and in the public interest.
The key question is not whether the doctor wants to practise again, but whether patients will be protected.
The Tribunal reviewed extensive evidence about what Dr. Doyle had done since losing his licence, including:
Years of intensive psychotherapy
Participation in a specialized physician rehabilitation program focused on boundaries, ethics, and judgment
Independent expert assessments concluding that he does not currently suffer from a mental illness affecting competence
Ongoing work in health-care settings without seeing patients
Evidence of greater insight, accountability, and life stability
Experts agreed that while some risk remains, it could be managed with tight controls.
The College opposed reinstatement, pointing out that:
The misconduct happened repeatedly over decades
Previous supervision and therapy had not prevented further problems
There was evidence the doctor continued giving advice to former patients even while suspended
Some experts still rated the risk of future misconduct as low to moderate
The College argued that public safety must come first.
After reviewing all the evidence, the Tribunal concluded that:
The doctor has made significant efforts to change
There is still some risk, but it can be controlled
Strict conditions can protect patients
Allowing a carefully limited return to practice would not undermine trust in the medical system
As a result, the Tribunal allowed reinstatement — but only with conditions, such as limits on the type of care provided, ongoing oversight, and safeguards around patient boundaries.
This decision highlights several important points for patients:
Patient safety is the top priority — reinstatement is only allowed if the risk can be managed
A revoked licence does not automatically mean a lifetime ban, but returning to practice requires strong proof of rehabilitation
Doctors who breach professional boundaries may face years of discipline, supervision, and restrictions
Regulatory bodies and tribunals closely scrutinize whether doctors truly understand and accept responsibility for past harm
The Tribunal did not say the doctor’s past conduct was acceptable. It found that the misconduct was serious and harmful. However, it concluded that — after years of treatment and monitoring — the doctor could return to practice only under strict conditions designed to protect patients.
For patients, the case underscores the importance of professional boundaries, proper care, and the role of medical regulators in responding when things go wrong.
Decision Date: January 12, 2026
Jurisdiction: Ontario Physicians and Surgeons Discipline Tribunal
Citation: Doyle v. College of Physicians and Surgeons of Ontario, 2026 ONPSDT 1 (CanLII)
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