Form T172 UK: Appeal Primary Health Lists Decision
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If a First-tier Tribunal (Primary Health Lists) has made a decision you disagree with, Form T172 is the route you use to ask for permission to appeal. It is a relatively short document, but getting it right matters because the Tribunal will weigh up your reasons carefully before deciding whether to let the appeal proceed.
On this page I have pulled together a plain-English walkthrough of what T172 actually asks for, the deadlines that apply, and the points people tend to trip up on. Whether you are a healthcare professional who has been removed from a performers list, contingently included, or subject to conditions, knowing how to frame your application clearly can make a real difference. Read on for a section-by-section guide to completing the form.
What this document is
Form T172 is the application used to ask the First-tier Tribunal (Primary Health Lists) for permission to appeal one of its decisions to the Upper Tribunal. Primary Health Lists cases typically involve GPs, dentists, pharmacists, and other primary care practitioners whose inclusion on an NHS performers or pharmaceutical list has been refused, suspended, removed, or made conditional by NHS England.
If you believe the Tribunal made an error of law when deciding your case, you cannot simply start a fresh appeal. You must first ask the Tribunal that heard your case for permission, and T172 is how you do it.
The form captures who you are, which decision you want to challenge, the legal errors you say occurred, and the outcome you want. Permission is not automatic. The Tribunal will look at whether your grounds genuinely raise an arguable point of law, rather than a disagreement with the findings of fact.
How to use this document
- Fill in your applicant details. Section A asks for your title, full name, postal address, professional registration number where relevant, phone number, and email. These contact points are how the Tribunal will reach you throughout the process, so double-check everything before moving on.
- Add your representative's details if you have one. Section B is for anyone acting on your behalf, such as a solicitor, barrister, or defence organisation representative. You will need their name, firm or organisation, address, profession, phone, and email. Note that once a representative is listed, all correspondence goes to them rather than to you.
- Identify the decision you are challenging. In Section C you set out the hearing venue, the hearing date, and the title and reference number of the decision. If more than 28 days have passed since the decision was sent to you, this is also where you must explain why the Tribunal should extend time and accept a late application.
- Set out your grounds of appeal. Section D is the heart of the form. You must identify the specific error or errors of law you believe the Tribunal made, and state the outcome you are asking for. Vague complaints will not succeed. Be precise, reference the part of the decision in question, and explain why it amounts to a legal error rather than a factual disagreement.
- Sign, date, and submit. Section E is for your signature and the date. Either you or your representative can sign, and a typed signature is acceptable. Once complete, send the form to the Tribunal office within the time limit so it can be considered without needing an extension of time.
Common questions
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Common questions
Q How long do I have to submit Form T172?
You generally have 28 days from the date the written decision was sent to you to submit an application for permission to appeal. If you miss that window, you can still apply, but you must explain in Section C why the application is late and ask the Tribunal to extend time. Late applications are not automatically refused, but the Tribunal will want a genuine reason for the delay.
Q What counts as an error of law?
An error of law might include applying the wrong legal test, failing to give adequate reasons, reaching a conclusion no reasonable tribunal could have reached on the evidence, or procedural unfairness during the hearing. Disagreeing with how the Tribunal weighed the evidence is usually not enough on its own. You need to point to something the Tribunal got wrong about the law itself or how it was applied.
Q Do I need a solicitor to complete Form T172?
No, you can complete and submit the form yourself. However, because the application must identify legal errors rather than factual disputes, many applicants choose to instruct a solicitor or get help from their medical defence organisation. Framing grounds of appeal correctly is a skill, and a weak application risks being refused permission without the substantive appeal ever being heard.
Q What happens after I submit the form?
The Tribunal will consider your application on the papers. It may grant permission, refuse it, or grant it on limited grounds only. If permission is refused, you can renew the application directly to the Upper Tribunal within a further time limit. If permission is granted, your appeal will proceed to be heard by the Upper Tribunal on the grounds allowed.
Q Is there a fee to apply using Form T172?
Fee arrangements for tribunal applications can change, so check the current position on gov.uk or with the Tribunal office before submitting. In many primary health list cases the process does not attract a fee at this stage, but it is sensible to confirm rather than assume. Do not let uncertainty about fees delay your submission past the 28-day deadline.
Q Can I include new evidence with my application?
Permission to appeal is about errors of law in the original decision, so new evidence that should have been before the original Tribunal is generally not the right route. If fresh evidence has come to light that could not have been produced at the hearing, mention it in your application, but do not rely on new evidence as your main ground. The focus should be on what the Tribunal did wrong in law.
If you're dealing with this kind of situation, speak to an experienced legal adviser who can walk you through it — from £89.
Sources
This guide is based on primary UK law and official guidance.
- Guidance · UK GovHM Courts and Tribunals Service: Form T172 on gov.ukgov.uk
- Guidance · HMCTSFirst-tier Tribunal (Primary Health Lists)gov.uk
- Guidance · UK GovAppeal to the Upper Tribunal (Administrative Appeals Chamber)gov.uk
Legal helpline
Not sure if you have grounds to appeal?
Permission to appeal turns on identifying a genuine error of law, which is a narrow test that trips up many applicants. An experienced legal adviser can help you think through what happened in your hearing and what might count as an arguable ground, based on what you describe on the call.
- Plain-English answers to your specific questions about the T172 process
- A clearer sense of what might count as an error of law in your situation
- Practical perspective on the 28-day deadline and extension of time
- Guidance tailored to what you describe about your Primary Health Lists decision
Legal disclaimer
This article is for general information only. It is a tool to help you find your way — not legal advice, and not a substitute for speaking to a qualified adviser about your situation.