Where an applicant with a discipline and criminal history applies for reinstatement, a committee considering that issue may account for various factors, including the impact of the applicant being reinstated on the public interest: Manoukian v. Ontario College of Pharmacists, 2017 ONSC 589.
In that case, a pharmacist’s certificate was revoked twice, first after he pled guilty in 1983 to trafficking in oxycodone [2-3], and after he obtained reinstatement in 1989 , a second time in 1996, after he was convicted of fraud based on his submitting false claims to the Ontario Drug Benefit Plan.  The pharmacist applied for reinstatement and submitted psychological and psychiatric assessments which indicated that his risk of reoffending was minimal.  A majority of a discipline hearing panel decided, however, to dismiss his application to be reinstated. 
The Ontario court decided the panel’s decision was reasonable. First, the panel properly had regard for the impact of the decision on the public.  Second, the panel did not improperly apply a standard of proof that was higher than a balance of probabilities.  Third, the panel was entitled to conclude that neither reinstatement with conditions nor the education programs taken by the applicant were sufficient to protect the public.  Fourth, the panel could determine the weight of the expert evidence of the risk to reoffend.  Finally, the court decided that its role was not to second-guess credibility findings of the panel.  Accordingly, the court concluded that reinstatement would pose a risk to the public, and also not reflect well on the profession, was reasonable. 
Manoukian v. Ontario College of Pharmacists, 2017 ONSC 589
Lisa C. Fong and Michael Ng