The Discipline Committee of the College of Veterinarians of Ontario has ordered Dr. Mohinder Bangar to serve a two-month suspension of his veterinary licence and pay $125,000 in costs1. The decision, dated January 27, 2025, follows an earlier finding that Dr. Bangar committed professional misconduct in his treatment of a patient, a cat named “Spots.”
This final decision concludes a lengthy and contested disciplinary proceeding, addressing not only the penalty and costs but also several motions brought by Dr. Bangar after he was found liable for misconduct.
The case originated from a Liability Decision released by the panel on April 23, 2024. In that decision, the Committee found that Dr. Bangar had failed to maintain the standards of practice of the profession and had engaged in conduct that would reasonably be regarded by other veterinarians as unprofessional. These findings related directly to his care of “Spots.” Following that decision, the process moved to the penalty and costs phase to determine the consequences of the misconduct.
Dr. Bangar proposed in May 2024 that this phase proceed through written submissions rather than an in-person hearing. As the parties exchanged materials over the following months, several disputes arose, requiring the panel to rule on three separate post-hearing motions before it could determine the final penalty.
The first motion, decided in August 2024, concerned the admissibility of evidence. Dr. Bangar sought to introduce information and discussions from the confidential pre-hearing conference held earlier in the proceedings. The College of Veterinarians opposed this, arguing that pre-hearing conferences are held on a “without prejudice” basis to allow for frank settlement discussions, as protected by Rule 19.2 of the Committee’s Rules of Procedure.
The panel denied Dr. Bangar’s motion. While acknowledging that confidential discussions might be admissible if they were needed to prove a settlement had actually been reached, the panel found that exception did not apply. The panel stated it “defies common sense” for the veterinarian to suggest a settlement was reached at the pre-hearing stage, only to then proceed through a “lengthy and fully contested hearing” where every allegation was disputed. The panel confirmed that no evidence from the pre-hearing conference was considered in its final decision.
The second motion involved a request by Dr. Bangar to introduce “fresh evidence.” This evidence was an article authored by a Dr. Wade Wright, which was published in May 2024, after the Liability Decision had been released. Dr. Bangar argued that the article undermined the expert opinion provided by the College’s witness, Dr. Markus Luckwaldt, during the merits phase of the hearing.
The panel dismissed the motion to reopen the merits phase. It ruled that the article did not meet the legal test for fresh evidence, primarily because Dr. Bangar had made a “strategic decision” not to call his own expert witness during the hearing to counter Dr. Luckwaldt’s testimony. The panel noted that counsel had cross-examined Dr. Luckwaldt with other articles but had failed to unsettle his opinions, and there was no reason to believe this new article would have affected the outcome. However, the panel did agree to accept and consider the article as part of Dr. Bangar’s submissions on the separate issue of penalty.
The third and most significant motion was a Disqualification Motion brought by Dr. Bangar in September 2024. He argued that two of the five members of the disciplinary panel had a conflict of interest. The basis for this claim was that these two members had previously been part of complaints committees that reviewed other, “wholly unrelated” complaints against Dr. Bangar. Those prior complaints had been dismissed and were not referred to discipline. Because the College sought to use this prior complaints history as an aggravating factor in the penalty phase, Dr. Bangar argued this created a reasonable apprehension of bias, and that the entire proceeding should be declared a “nullity in law.”
The College argued there was no bias, actual or perceived, and that prior involvement in unrelated, non-referred complaints does not disqualify a panel member. The panel decisively dismissed this motion. It stated there was “no basis whatsoever” to suggest any panel member had shown bias. It also explicitly stated that it would not consider the prior, non-referred complaints as aggravating factors when determining the penalty.
With the motions dismissed, the panel turned to the submissions on penalty. The College sought a significant penalty, including an oral reprimand, a four-month licence suspension, and extensive remedial conditions. These included assessments, unannounced records reviews, and mandatory mentorship or courses on both medical issues and client communication. The College argued these measures were necessary for deterrence and to maintain public confidence, citing Dr. Bangar’s prior complaints history as an aggravating factor.
Dr. Bangar argued the College’s proposed penalty was “excessive, punitive, and unwarranted.” He submitted that he should face no penalty or, at most, a suspended penalty. He characterized himself as a first-time offender with no prior disciplinary history, highlighted his proactive participation in the Peer Advisory Program, and submitted numerous letters of support. He also pointed to the Dr. Wright article as supporting his treatment of “Spots,” which he described as “an elderly cat at the end of its life” for whom he “did his best.”
The panel ultimately ordered a penalty that fell between the two positions. It ordered Dr. Bangar to appear for an oral reprimand and directed the Registrar to suspend his licence to practice veterinary medicine for a period of two months. The panel also imposed several conditions, including a baseline assessment (paid by the College), unannounced records reviews (paid by Dr. Bangar), a one-day mentorship or course on the medical issues from the case (paid by Dr. Bangar), a one-day course on client relations (paid by Dr. Bangar), and a final post-remediation assessment (paid by the College).
In its reasons for the penalty, the panel characterized Dr. Bangar’s conduct as “unprofessional” and his treatment of Spots as “deficient in broad and numerous ways.” The panel stated that while it accepted Dr. Bangar “truly did the best that he felt he could,” his best “was nowhere near good enough and he must learn to do better.” It found a reprimand was necessary to denounce the conduct and a suspension was required for both specific and general deterrence.
However, the panel did not agree with the College’s request for a four-month suspension, finding it “too long based on all the circumstances.” After reviewing case precedents, the panel determined a two-month suspension was appropriate, especially given Dr. Bangar’s “commitment to remediation.” The panel also explicitly rejected the College’s submission that Dr. Bangar’s prior complaints history was an aggravating factor, noting none of those matters were referred for discipline. It also gave little weight to the Dr. Wright article, as the author was not available for testimony, and rejected the veterinarian’s submission that his recent purchase of the clinic was a mitigating factor.
Finally, the panel addressed the issue of costs. The College sought $150,195.07, representing about two-thirds of its actual costs, which exceeded $225,000. The College argued this was justified by the serious findings and the conduct of the defense. Dr. Bangar argued the amount was “grossly disproportionate” and punitive. He cited an Alberta case, Jinnah v. Alberta Dental Association and College, to argue that the costs should be borne by the profession as a whole. He further submitted that if the panel found the proceedings were “unwarranted,” the College should be ordered to pay him $50,000.
The panel rejected Dr. Bangar’s submissions, stating his claim that the proceedings were unwarranted was “not credible” given the “numerous, serious, findings of professional misconduct.” The panel also rejected the Jinnah case, stating it is not a binding authority in Ontario and that Ontario law permits ordering costs against a member.
The panel found that the College had proved the majority of its allegations and was “wholly successful” on the numerous contested motions. It also noted that while a veterinarian has the right to mount a vigorous defense, the conduct of Dr. Bangar’s counsel, including “needlessly longer” and “ineffective” cross-examinations, had lengthened the proceedings.
While the panel agreed that costs were warranted, it found the $150,195.07 requested by the College was “too high in all of the circumstances.” It determined that $125,000 was an appropriate amount, falling within the range of comparable complex cases. The panel ordered that Dr. Bangar could pay the amount in twelve monthly instalments or another arrangement agreed to with the College, to address the financial burden on his small practice.
