Ms Shereen Doummar

THE ARCHITECTS REGISTRATION BOARD

PROFESSIONAL CONDUCT COMMITTEE

In the matter of

SHEREEN MARIA DOUMMAR
(095981B)

Held as a virtual hearing on:

2 March 2026
———
Present
Sean Hammond (Chair)
Robert Dearman (PCC Architect Member)
Alistair Cannon (PCC Lay Member)
———–

In this case, the Architects Registration Board (“ARB”) is represented by Ms Rachel Birks from Ward Haddaway (“the Presenter”).
Ms Shereen Doummar (the “Registered Person”) has attended this hearing and is legally represented by Mr Edward David from Janner and Block LLP.

 

Allegation

1. The Registered Person faces an allegation of unacceptable professional conduct (“UPC”) in that:

1) The Registered Person did not ensure that they had adequate professional indemnity insurance when undertaking work as an architect between the period of November 2023 and April 2024.

Background

2. The Registered Person is a registered architect.

3. The Registered Person started her own practice, ATMA Studio Ltd, in June 2020.

4. The Registered Person had not undertaken any architectural work since the start of her practice until November 2023, when she was introduced to her client through family contacts. The engagement was informal and involved providing conceptual services to the client in relation to a project.

5. The ARB received a complaint from the client. On 8 September 2025, ARB issued a letter to the Registered Person detailing the complaint and inviting the Registered Person to provide her representations in response.

6. On 17 September 2025, the Registered Person provided her response.

7. In her response to the complaint, the Registered Person noted that she did not have professional indemnity insurance (“PII”) in place between November 2023 and April 2024, the duration of the Project.

8. The Registered Person explained that she did not consider PII was necessary due to the informal nature of the engagement and that the client’s instruction was to complete a conceptual exploration of his site and identify potential pragmatic uses, which in her view was not architectural or technical works. She further explained that should the works have progressed to a later stage, it would have been her intention to execute a formal contract with the client with the necessary PII cover in place.

9. In her response, the Registered Person accepted that she did not have PII cover in place, but that it was not her intention to be in breach of the Architects Code: Standards of Professional Conduct and Practice 2017 (“the Code”). She confirmed that she would take the necessary steps to obtain adequate PII cover in order to remedy this error.

Admissions

10. The allegation was put to the Registered Person and Mr Davis informed the Committee that the Registered Person admitted the facts in particular 1 of the allegation.

11. Mr Davis, whilst acknowledging that it was ultimately a matter for the Committee’s independent judgement, informed the Committee that the Registered Person also admitted that her conduct amounted to UPC.

Findings of Fact

12. The Committee was satisfied that the Registered Person’s admission to the facts was unequivocal and made with the benefit of legal advice.

13. The Committee therefore found the facts in particular 1 of the allegation proved pursuant to Rule 25(d) of the Architects Registration Board (Professional Conduct Committee) Rules 2022 (“the Rules”).

Unacceptable Professional Conduct

14. Having found particular 1 of the allegation proved, the Committee went on to consider whether the Registered Person’s conduct amounted to UPC.

15. The Committee heard submissions from the Presenter and Mr Davis.

16. The Committee accepted the advice of the Legally Qualified Chair, which was given in open session.

17. The Committee reminded itself that notwithstanding the Registered Person’s admission, a finding of UPC is a matter for its own independent judgement having regard to the facts found proved.

18. The Committee noted that UPC is defined in section 14(1)(a) of the Architects Act 1997 as conduct which falls short of the standard required of an Architect.

19. The Committee further noted that Misconduct, which is akin to UPC, was defined in the case of Roylance v GMC [2000] 1 AC 311 as:

“a word of general effect, involving some act or omission which falls short of what would be proper in the circumstances. The standard of propriety may often be found by reference to the rules and standards ordinarily required to be followed by a medical practitioner in the particular circumstances”.

20. In this case, the standards required to be followed by the Registered Person are contained in the Code.

21. The Committee noted that, in accordance with Rule 21 of the Rules, it is required to take into account any failure by the Registered Person to comply with the provisions of the Code when reaching its decision on UPC. However, the Committee recognised that not every shortcoming on the part of an architect, nor failure to comply with the provisions of the Code, will necessarily result in a finding of UPC.

22. The Committee noted that it was confirmed in the case of Vranicki v Architects Registration Board [2007] EWHC 506 (Admin) that any failing on the part of the Registered Person must be serious. The Committee also had regard to the judgments in the cases of Nandi v GMC [2004] EWHC 2317, in which the court held that “the adjective ‘serious’ must be given its proper weight, and Spencer v General Osteopathic Council [2012] EWHC 3147 (Admin) where the Court held that for a finding of UPC to be made, “a degree of moral blameworthiness on the part of the registrant likely to convey a degree of opprobrium to the ordinary intelligent citizen” is required.

23. In the Committee’s view, the Registered Person’s actions fell short of the following Standards of the Code:

Standard 8.1:

“You are expected to have adequate and appropriate professional indemnity insurance cover for you, your practice and your employees. You should ensure that your insurance remains adequate to meet a claim. You are expected to maintain a minimum level of cover, including run-off cover, in accordance with ARB’s guidance.”

24. The Committee also had regard to the ARB’s published guidance in relation to PII. In particular, it noted paragraphs 2.1 and 2.7, which state:

“2.1 Allegations of professional negligence often involve complex and detailed issues, and litigation may be expensive. Even where an architect has found not to be at fault, the costs in defending a claim can far exceed the fees the practice has earned on a project. An uninsured claim can leave clients and the public with no reasonable route of redress, and be ruinous for an architect’s practice.”

“2.7 There is a strong public interest in architects maintaining proper professional indemnity insurance so that clients and building users have a route to redress in the event of a negligence claim. Because of that ARB, acting through our Professional Conduct Committee, will view very seriously any failure by an architect in this regard.”

25. In the Committee’s view, these two paragraphs of the ARB’s guidance, clearly set out the importance of ensuring that appropriate and adequate PII cover is in place. Those paragraphs identify not only the risk of harm to clients and architects if PII cover is not in place, but also the wider public interest in maintaining public confidence in the profession by ensuring that architects have appropriate and adequate PII cover in place to provide clients and building users with a route of redress in the event of a claim being made.

26. In this case, the Committee was satisfied that although there is no evidence of actual harm to the client, the Registered Person’s failure to ensure that appropriate and adequate PII cover was in place, exposed the client to a potential risk of harm. In addition, although this was an isolated incident involving only one client, the Registered Person’s conduct spanned a period of five months.

27. In the Committee’s view, the Registered Person’s failure to ensure that she had appropriate and adequate PII cover in place for the duration of the client’s project between November 2023 and April 2024 amounted to a significant breach of Standard 8.1. The Committee was satisfied that the Registered Person’s conduct fell below the standard expected of a registered Architect and was sufficiently serious to amount to UPC.

28. For the reasons set out above, the Committee therefore found the Registered Person guilty of UPC.

Sanction

29. Having found the Registered Person guilty of UPC, the Committee next considered what, if any, sanction to impose in this case.

30. In reaching its decision, the Committee had regard to all documentary evidence provided to it and took into account the submissions made by the Presenter and Ms Davis.

31. The Committee had regard to and applied the Professional Conduct Committee Sanctions Guidance (2022) (“the Sanctions Guidance”) published by the ARB and accepted the advice of the Legally Qualified Chair, which was given in open session.

32. The Committee reminded itself that the primary purpose of sanctions is to protect members of the public, to maintain public confidence in the profession, and to declare and uphold proper standards of conduct and competence.

33. It has borne in mind that the purpose of imposing a sanction is not to be punitive but recognised that it may have a punitive effect. In reaching its decision, the Committee has considered the Registered Person’s interests and the need to act proportionately.

34. The Committee noted that in some cases, it may determine that the level of seriousness of the architect’s conduct is so low, that it would be unfair or disproportionate to impose a sanction. It further noted that in cases where it determines that the level of seriousness is such that a sanction is required, then the available sanctions are:

I. A Reprimand;
II. A Penalty Order;
III. A Suspension Order (for a maximum of two years); and
IV. Erasure.

35. In accordance with the Sanctions Guidance, the Committee considered the seriousness of the case.

36. The Committee first considered whether there were any aggravating factors. In so doing, the Committee had regard to the list of common examples of aggravating factors set out in paragraph 5.3.1 of the Sanctions Guidance.

37. The Committee noted that the Presenter submitted that the only factor engaged, was the Registered Person’s lack of sufficient insight and remorse. The Presenter submitted that the Registered Person’s admissions in this hearing were to save time and costs, rather than a recognition or acceptance on her part that her conduct fell far short of the standards expected of a registered architect.

38. The Committee also noted that Mr Davis invited the Committee to reject this submission and that he referred the Committee to the Registered Person’s written responses to the ARB and her recent 12-page statement.

39. Having considered this material, the Committee was satisfied that through her admissions, explanations, reflection and remedial conduct, the Registered Person has demonstrated sufficient insight and remorse into her conduct.

40. The Committee determined that there were no aggravating factors in this case.

41. The Committee next considered whether there were any mitigating factors. It had regard to paragraph 5.3.2 of the Sanctions Guidance.

42. The Committee identified the following mitigating factors:

I. In the particular circumstances of this case, there was no actual harm to the client and/or the wider public and the risk of harm was low.
II. The Registered Person’s conduct as an isolated incident involving one client.
III. The Registered Person has demonstrated insight and remorse.
IV. The Registered Person made open and frank admissions at an early stage of these proceedings and also made a formal admission during this hearing.
V. The Registered Person has provided evidence of remedial action she has taken; namely proof that she has made arrangements for appropriate and adequate PII cover to be in place from 12 December 2025 until 11 December 2026.
VI. The Committee was satisfied, having regard to the level of insight demonstrated by the Registered Person and the remedial action that she has taken, that the risk of repetition is low.
VII. The Registered Person is a person of good character. She has no previous disciplinary findings recorded against her. Furthermore, the Committee considered that her voluntary repayment of the client’s fees is indicative of her integrity.

43. Having found that there were no aggravating factors, but having identified numerous mitigating factors, the Committee determined that this case falls towards the lower end of the spectrum of seriousness of such cases.

44. The Committee next considered whether this was a case where it would unfair and disproportionate for it to impose a sanction. The Committee had regard to the guidance in paragraphs 6.1.1 and 6.1.2 of the Sanctions Guidance. The Committee was of the view that, although this case was towards the lower end of the spectrum of seriousness, it nevertheless involved a significant breach of Standard 8.1 of the Code and was not so low as to fall into the exceptional category where no sanction is required.

45. The Committee therefore considered the available sanctions in ascending order.

46. The Committee noted the guidance in respect of Reprimands in the Sanctions Guidance, in particular, the Committee had regard to paragraph 6.2.2, which states:

“A reprimand may be considered appropriate where one or more of the following factors are present (this list is not exhaustive):
• There is no evidence that the architect poses a risk to the public;
• The conduct and/or incompetence found has not seriously affected clients
or the wider public;
• There is evidence of genuine insight and remorse;
• The architect has taken corrective steps;
• There is evidence of previous good disciplinary history;
• The conduct and/or incompetence found represents an isolated incident;
• The architect’s actions were not deliberate.”

47. The Committee was satisfied that all the factors listed in the bullet points applied in this case.

48. The Committee therefore determined that a Reprimand was the appropriate and proportionate order in this case.

49. In accordance with the Sanctions Guidance, the Committee ‘tested’ its decision by considering the following, more severe, sanction namely a Penalty Order, to determine why that would not be appropriate or proportionate in the circumstances of the case. The Committee had regard to the factors listed in paragraph 6.3.2 where a Penalty Order may be considered appropriate. In the Committee’s view, none of those factors applied in this case. The Committee therefore determined that a Penalty order would be both inappropriate and disproportionate.

50. The Committee therefore imposes a Reprimand.