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IN THE MATTER OF A POLICE MISCONDUCT HEARING
PURSUANT TO THE POLICE (CONDUCT) REGULATIONS 2020
NORTHUMBRIA POLICE
Appropriate Authority
v.
DS 551 CHRISTOPHER HOGG
NOTICE UNDER REGULATION 43
OUTCOME OF MISCONDUCT HEARING
Hearing Details
18th - 19th August 2026 held in person at Houghton le Spring Police Station, Dairy Lane, Tyne & Wear DH4 5BH.
Panel
ACC Alastair Simpson – (Chair)
Mr. John Robinson (Independent Panel Member)
Mrs. Sue Pearce (Independent Panel Member)
Mr. Adeolu Odusote (Legally Qualified Person)
Representatives
Counsel for the Appropriate Authority – Mr. Daniel Penman
Counsel for the officer – Mr. Christopher Hopkins
Terminology
“AA” - Appropriate Authority
“LQP” - Legally Qualified Person (the legal advisor to the Panel)
“The officer” – DS Christopher Hogg
“The Guidance” - College of Policing Guidance on Outcomes on Police Misconduct Proceedings.
Introduction
1. This is the record of a Police Misconduct Panel held under the Police (Conduct) Regulations 2020 (as amended) into the conduct of the former officer.
2. The hearing was conducted in person at Houghton le Spring Police Station, Dairy Lane, Tyne & Wear DH4 5BH. Members of the public were permitted to attend; one member of the public was in attendance. The officer was present throughout the hearing.
3. It had been agreed by both parties in advance of the hearing that anonymity would be granted to a member of the public. This person is referred to as “C” in this Regulation 43 report.
4. During this hearing, live oral evidence was heard from the following witnesses:
i) a former police constable who was serving at the time
ii) a Detective Inspector
iii) The Officer
5. The Regulation 30 Notice was served on the officer which specified a number of allegations. To assist the reader of this Regulation 43 notice, the allegations contained within the Regulation 30 notice have been copied into this notice as per below.
Allegation 1
(a) On 10 January 2025 DS Hogg amended the DMM document relating to Person C to state that consent was not given for a search. That amendment was untrue as consent had been given, and DS Hogg knew that it was untrue.
(b) This conduct is a breach of the Honesty and Integrity, and Discreditable Conduct Standards of Professional Behaviour:
(i) Knowingly entering untrue information into a police document as though it were true is dishonest;
(ii) Knowingly entering untrue information into a police document as though it were true undermines public confidence in policing.
Allegation 2
(a) On 10 January 2025 DS Hogg told a Detective Inspector that the reason for the discrepancy between the DMM document and the NPICCS record was that there had been a mix up on the DMM from the late shift. That was untrue, as the reason for the discrepancy was his amendment of the DMM, and DS Hogg knew it was untrue.
(b) This conduct is a breach of the Honesty and Integrity, and Discreditable Conduct Standards of Professional Behaviour:
(i) Knowingly giving untrue information to a superior officer is dishonest;
(ii) Knowingly entering untrue information to a superior officer undermines public confidence in policing.
Allegation 3
(a) On 10 January 2025 DS Hogg told the former police constable to change back information that they had changed on the NPICCS record, because a Detective Inspector was aware of their original account.
(b) This conduct is a breach of the Honesty and Integrity, and Discreditable Conduct Standards of Professional Behaviour:
(i) Attempting to cover up the fact that you have amended documentation is dishonest and/or lacking in integrity;
(ii) Attempting to cover up the fact that you have amended documentation undermines public confidence in policing.
Taken individually and cumulatively the above breaches are alleged to amount to Gross Misconduct
Purpose of Misconduct Proceedings
6. In R (On the application of Redgrave) v Commissioner of Police of the Metropolis [2003] EWCA Civ 4 at [33], Simon Brown LJ made it clear that the character and purpose of misconduct proceedings was
“to protect the public .... and to maintain the high standards and good reputation” of the policing profession.”
7. In R (Green) v Police Complaints Authority [2004] UKHL 6 Lord Carswell stated [para 78]:
“Public confidence in the police is a factor of great importance in the maintenance of law and order in the manner which we regard as appropriate in our polity. If citizens feel that improper behaviour on the part of police officers is left unchecked and they are not held accountable for it in a suitable manner, that confidence will be eroded.”
The Panel’s Approach
8. During this hearing, the Panel took the following approach:
i) First, to consider the facts of the case and to make findings in relation to each of the facts alleged by the AA.
ii) Second, to determine whether those facts found proved constituted one or more breach(es) of the relevant standards.
iii) Third, to determine whether any conduct found proven against the officer amounted to misconduct or gross misconduct.
iv) Fourth, and if appropriate, to decide what the outcome should be.
9. The Panel reminded itself that the burden of proof was upon the AA throughout the hearing and that the standard of proof to be applied to this case was upon the balance of probabilities, namely what was more likely than not to have occurred.
10. The Panel also reminded itself of the Home Office Guidance (Conduct, Efficiency and Effectiveness: Statutory Guidance on Professional Standards, Performance, and Integrity in Policing, 2020) and, in particular, paragraph 9.10 which states:
“In deciding matters of fact, the persons conducting the misconduct meeting or hearing must apply the standard of proof required in civil cases, that is, the balance of probabilities.”
11. In approaching its task, the Panel had borne in mind that:
i) They did not have to decide every matter of dispute, only those which assisted them to whether those allegations were proved.
ii) That they could draw inferences from the evidence submitted to them, meaning they could reach common sense conclusions from the evidence, but that they should guard against falling into speculation when reaching those conclusions.
Documents and Evidence
12. The Panel were provided with the following documents and evidence in advance of the hearing:
a) A main bundle of 101 pages that had been agreed by both parties.
13. The AA provided the Panel with a helpful opening note.
Findings of Fact
14. The panel find there are a number of undisputed facts of relevance in this case:
15. Two police constables, one of which was the former police constable identified above, attended FIG BB/105/24 on 9th January 2025 and updated the DMM, FIG and NPICCS record later that evening in a consistent manner. They represented that they spoke to the occupants, that consent would have been given for a search if required but that no search was carried out due to lack of necessity and time.
16. At 08.18 on 10th January 2025, DS Hogg amended the DMM record to state that ‘no consent was given and therefore no search was carried out’. He did so without having spoken to either the former police constable, or the other police constable and without reviewing the intelligence submission on NPICCS.
17. Around 11.00 on 10th January 2025, DS Hogg spoke briefly to the former police constable before going into a meeting with the Detective Inspector.
18. During the meeting with the Detective Inspector, they pointed out a discrepancy between the DMM record for BB/105/24 and the NPICCS record and asked DS Hogg about it.
19. The former police constable changed the intelligence records between 11.42 and 11.48 that morning.
20. DS Hogg had a conversation with the former police constable after leaving the meeting with a Detective Inspector.
21. The former police constable changed the intelligence records back to their original text between 11.59 and 12.04 on 10th January 2025.
22. The former police constable spoke to the Detective Inspector at 12.52hrs on 10th January 2025 and reported being unhappy about what he had been asked to do by DS Hogg.
23. There are a number of questions addressed by the panel in their deliberations around findings of fact. These have assisted the panel in reaching conclusions on the evidence. All of the findings are on the balance of probabilities.
Why did DS Hogg change the DMM?
24. The panel accept the evidence of the former police constable, that DS Hogg was unhappy with the entry on the DMM made by both the former police constable and his police constable colleague the night before. The panel accept the evidence of the former police constable that DS Hogg told him around 11.00am that morning that he changed it because it was shoddy work and he wanted to avoid scrutiny. He would have known that the approach taken by both the former police constable and the police constable was not in line with expectations.
What did DS Hogg say to the former police constable immediately prior to meeting a Detective Inspector
25. The panel prefer the evidence of the former police constable to DS Hogg on this point. The panel believe that the former police constable was instructed, either expressly or implicitly to change the intelligence records to match the DMM. This is consistent with the other evidence in the case.
Why did the former police constable change the intelligence records to match the DMM entry created by DS Hogg.
26. The panel find he did so because he was instructed to do so, expressly, or implicitly, by DS Hogg. There is no other reasonable explanation for the former police constable to change the records.
What did DS Hogg say to a Detective Inspector about the reason for the discrepancy between the DMM entry and the NPICCS entry.
27. The panel prefer the evidence of the Detective Inspector that he told them it was due to a mix up between late shift and early shift. However, there is no material difference with the account of DS Hogg who reported a ‘misinterpretation.’
What did DS Hogg say to the former police constable after the meeting with the Detective Inspector?
28. The panel prefer the evidence of the former police constable over DS Hogg. The panel believe that DS Hogg immediately spoke to the former police constable and asked him to change the intelligence records back to the original content as the Detective Inspector was aware of the discrepancy and he had told them there was a mistake. This is consistent with the other evidence in the case. The panel find DS Hogg’s explanation lacked credibility.
Why did a police constable change the NPICCS records back to the original text?
29. The panel find that the former police constable changed the intelligence records back as they had been instructed to do so by DS Hogg.
What did DS Hogg say to the former police constable after they told him they had informed the Detective Inspector, and why did he say that?
30. The panel prefer the evidence of the former police constable. The panel find that DS Hogg said to the former police constable ‘So, you’ve thrown me under the bus; thanks very much, I’ll not forget this.’ The panel also accept the evidence of the former police constable that on the 13th of January 2025, DS Hogg said to them ‘thanks for that (former officer)’ as he was led out of the department.
Allegation 1
31. (a) On 10 January 2025 DS Hogg amended the DMM document relating to Person C to state that consent was not given for a search. That amendment was untrue as consent had been given, and DS Hogg knew that it was untrue.
32. The panel find that DS Hogg knew at the time he did so that he should not have changed the record. He was in no place to do so as he was not present at the time, he had not spoken to either officer and he had not reviewed all of the intelligence. On the balance of probabilities, he did so to avoid scrutiny for his team. In amending the record, the panel find that DS Hogg lacked integrity. However, the wording of allegation 1 requires the panel to find on the balance of probabilities that DS Hogg knew the changes he made to be untrue. The standard of proof has not been reached in relation to Allegation 1 as the panel is not satisfied on the balance of probabilities that DS Hogg knew the changed statement to be untrue. The panel find that the effect of his action was to change the meaning of the sentence to represent that consent was refused and this was why the search was not carried out but we do not feel at 8.18 that morning that he was deliberately seeking that effect.
33. The panel finds allegation 1 not proven.
Allegation 2
34. On 10 January 2025 DS Hogg told the Detective Inspector that the reason for the discrepancy between the DMM document and the NPICCS record was that there had been a mix up on the DMM from the late shift. That was untrue, as the reason for the discrepancy was his amendment of the DMM, and DS Hogg knew it was untrue
35. The panel finds that before going into the meeting with the Detective Inspector, DS Hogg knew that he has amended the DMM entry and when the Detective Inspector brought up the discrepancy he was dishonest in his response that there was a mix-up or some misinterpretation as he knew the amendment causing the discrepancy was made by him.
36. DS Hogg claimed that he wanted to clarify the entry with the former police constable before getting back to the Detective Inspector. This is inconsistent with the actions he later undertook. The evidence of both police constables is that he immediately called the former police constable into another room and asked them to change it back. He never asked for a clarification of the initial DMM entry.
37. The panel prefers the evidence of the former police constable. DS Hoggs account lacks credibility and the panel find allegation 2 proven.
Allegation 3
38. On 10 January 2025 DS Hogg told the former police constable to change back information that they had changed on the NPICCS record, because the Detective Inspector was aware of the former police constable’s original account
39. The panel prefers the evidence of the former police constable over the evidence of DS Hogg. The former police constable was not in the meeting with the Detective Inspector and DS Hogg but accurately represented what they said to DS Hogg when he reported the conduct to them.
40. A further police constable heard the words “change back” in a discussion between the former police constable and DS Hogg.
41. The panel finds that the former police constable changed the NPICCS records back to the original text because DS Hogg asked him to do so and that his behaviour was dishonest.
42. The panel find allegation 3 proven.
Determination of Breaches of the Standards of Professional Behaviour
43. Having conducted the fact-finding assessment against each of the disputed facts in this hearing, the Panel then determined which of the alleged breaches of the Standards of Professional Behaviour (SPB) had been proven by the AA against the former officer.
44. The Panel reminded itself once again that the burden of proof had been upon the AA throughout the hearing and that the standard of proof required was upon the balance of probabilities, namely what is more likely than not to have occurred.
Alleged Breach: Honesty and Integrity
45. The Panel found that the officer’s actions in respect of allegations 2 and 3 were dishonest. Accordingly, the panel concluded this standard was breached.
46. In the circumstances, the Panel determined that the officer’s proven conduct amounted to a breach of SPB, namely Honesty and Integrity.
Alleged Breach: Discreditable Conduct
47. The Panel considered whether the officer’s proven conduct in relation to Allegations 2 and 3 would bring discredit upon the police service. The Panel found that it would, as the officer’s actions were likely to undermine public confidence in the police. A reasonable member of the public would be concerned that a police officer had behaved in this manner.
48. In the circumstances, the Panel determined that the officer’s proven conduct amounted to a breach of SPB, namely Discreditable Conduct.
Misconduct or Gross Misconduct
49. The panel next considered its determination of the seriousness of the allegations found proven. In making this determination, the panel have given regard to the College of Policing Guidance on Outcomes on Police Misconduct Proceedings to assist them in their assessment
50. They noted that this guidance identifies certain categories of misconduct as being especially serious.
51. The Panel reminded itself that Regulation 2(1) of the 2020 Regulations defines misconduct as being ‘a breach of the standards of professional behaviour that is so serious as to justify disciplinary action’ whilst gross misconduct is defined as ‘a breach of the standards of professional behaviour that is so serious as to justify dismissal’.
52. The Panel further reminded itself that the purpose of the police misconduct regime is to: maintain public confidence in and the reputation of the police service; uphold high standards in policing and deter misconduct; and protect the public.
53. The panel noted paragraph 4.1 of the Guidance on Outcomes which states that ‘whether conduct would if proven, amount to misconduct or gross misconduct for the purposes of Regulation 14 of the Conduct Regulations is also a question of degree (i.e., seriousness)’.
54. The panel were also mindful of Paragraph 4.3 of the guidance which advises that an assessment of seriousness of the proven misconduct is by reference to:
i) the officer’s culpability for the misconduct
ii) the harm caused by the misconduct
iii) the existence of any aggravating factors
iv) the existence of any mitigating factors
55. The panel were also assisted by Fuglers LLP v Solicitors Regulation Authority [2014] EWHC 179 (Admin), paragraph 29: ‘In assessing seriousness the most important factors will be (1) the culpability for the misconduct in question and (2) the harm caused by the misconduct. Such harm is not measured wholly, or even primarily, by financial loss caused to any individual or entity. A factor of the greatest importance is the impact of the misconduct upon the standing and reputation of the profession as a whole. Moreover, the seriousness of the misconduct may lie in the risk of harm to which the misconduct gives rise, whether or not as things turn out the risk eventuates. The assessment of seriousness will also be informed by (3) aggravating factors (e.g., previous disciplinary matters) and (4) mitigating factors (e.g., admissions at an early stage or making good any loss).
Culpability
56. The panel first turned to an assessment of culpability and were assisted by paragraphs 4.9 - 4.16 of the guidance.
57. Para 4.10 of the guidance states that Conduct that is intentional, deliberate, targeted, or planned will generally be more culpable than conduct that has unintended consequences, although the consequences of the former officer’s actions will be relevant to the harm caused. The actions of DS Hogg in being dishonest with the Detective Inspector and dishonestly requesting the former police constable ‘change the records back’ were a deliberate attempt to avoid responsibility for his own wrongdoing in altering the DMM record. Para. 4.10 of the guidance is engaged in the panel’s assessment of the officer’s culpability
58. Paragraph 4.12 states that culpability will be increased when an officer holds a position of trust or responsibility at the relevant time. The officer was in a position of responsibility as a Detective Sergeant and in a position of trust as an experienced Intelligence Officer. He should have known better. The officer’s actions transpired over the course of a single morning so were not sustained but is clear that over the course of the morning the officer realised he had done something wrong and made no attempt to admit and rectify his own errors, rather seeking to cover his own back by placing pressure on a junior officer. Para. 4.12 of the guidance is engaged in the panel’s assessment of the officer’s culpability.
59. Para. 4.27 of the guidance states that Operational dishonesty is dishonesty in connection with a police operation. The panel finds that this this is operational dishonesty. The integrity of intelligence systems is of paramount importance as intelligence held on police systems will be relied upon to guide future decision making. This is particularly serious with decisions of high consequence, such as firearms operations. The officer was an experienced intelligence officer and must have appreciated this. Para 4.27 of the guidance is therefore engaged in the panel’s assessment of the officer’s culpability. The panel finds the officer’s culpability as High.
Harm
60. The panel next turned to their assessment of the harm caused by the officers in this incident. They were assisted by paragraphs 4.63 - 4.64 of the guidance.
61. Para 4.65 of the guidance states that Misconduct may affect particular individuals, in which case the harm caused may depend on the victim’s personal characteristics and circumstances.
62. No actual harm occurred as the issue was found by the Detective Inspector. However, had they not done so, the panel believe that DS Hogg would not have intervened to change the record to its original format.
63. Harm was caused to the former police constable. The actions of the officer caused the former police constable to be uncomfortable and upset. It placed them in a very difficult position, which caused them stress. The comments made to the former police constable about ‘being thrown under the bus’ and ‘thanks a lot’ [reference being moved out of the department] further and unfairly added to the stress on him. Para 4.65 is therefore engaged in the panel’s assessment of harm.
Effect on the police service and/or public confidence
The panel then considered the harm to the police service and/or public confidence engaged by the proven actions and inactions of the officers. They were assisted by paragraph 4.66 of the guidance.
64. The guidance at paragraph 4.66 states that harm will likely undermine public confidence in policing. The guidance further states that for the purposes of assessing seriousness, harm does not need to be suffered by a defined individual to undermine public confidence.
65. The guidance states that where an officer commits an act that would harm public confidence if the circumstances were known to the public, this should be taken into account.
66. The panel finds that there is harm to confidence in police intelligence systems. Northumbria Police and other law enforcement agencies seek to rely on intelligence as accurate. Police intelligence is used to guide decision making which can have significant consequences to the public. Any lack of integrity of the intelligence systems undermines the grounds on which such decisions are made and may lead to the use of disproportionate police tactics against members of the public. The willingness of an experienced intelligence officer and Detective Sergeant to change intelligence records undermines public and law enforcement confidence in force intelligence.
67. There is clearly a harm to public confidence. The public expect that officers will be honest with their superiors. An officer who is dishonest in order to cover his own back and who places pressure on a junior officer to avoid detection seriously undermines the trust that the public should be able to place in police officers. The panel finds the Harm as High
Aggravating Factors
68. The panel were assisted by paragraphs 4.75-4.78 of the guidance in their assessment of aggravating factors in this case. The guidance states that when certain factors are engaged, the level of culpability or harm may increase.
69. The officer attempted to conceal his wrongdoing and sought to blame others.
70. The officer placed pressure on a junior officer to avoid personal responsibility for his own error.
Mitigating Factors
71. The panel were assisted by paragraphs 4.79 - 4.82 of the guidance in their assessment of mitigating factors in this case. The guidance states that mitigating factors are those tending to reduce the seriousness of the misconduct. The guidance states that some factors may indicate that an officer’s culpability is lower, of that the harm caused by the misconduct is less serious than it might otherwise have been.
72. On the basis of the character reports and the evidence presented to the panel, the behaviour displayed on this occasion was out of character for DS Hogg. He has a history of long service as a good officer.
73. The officer has suggested that personal circumstances impacted on his behaviour that day. The panel are not persuaded that this was an operating factor which excuses his decision making.
Decision on Level of Breach
74. Having carefully considered the contents of the Guidance on Outcomes, the Police Code of Ethics, the panel found that the proven actions by DS Hogg were at the upper end of seriousness.
75. The panel found that the breaches of the Standards of Professional Behaviour by DS Hogg were so serious that they could justify dismissal as a potential outcome.
76. The panel therefore found that the proven breaches of the Standards of Professional Behaviour by DS Hogg amounted to Gross Misconduct in respect of allegations 2 and 3.
Decision on Outcome
77. As provided in paragraphs 56 - 70 in this Regulation 43 report, the panel have presented their assessment of seriousness against the four elements described in the guidance i.e. culpability, harm, aggravating factors, and mitigating factors. This assessment was carried out in accordance with paragraphs 4.1- 4.3 of that guidance to assist the panel in determining whether the proven conduct amounted to misconduct or gross misconduct (the level of breach).
78. Following its decision on the level of breach, the panel were provided with submissions from both parties against those same factors for the purposes of assisting them in determining the outcome in this hearing.
79. The panel had regard to the threefold purposes for imposing misconduct outcomes which are:
i) Maintaining public confidence in and the reputation of the police service;
ii) Upholding the high standards in policing and deterring misconduct; and
iii) Protecting the public.
80. Having again carefully considered culpability and harm in accordance with the guidance, the Panel’s starting point for seriousness was unchanged and was deemed to be High.
81. The panel received representations from the officer that the conduct was not operational dishonesty. The panel set out reasons for this judgment at Paragraph 59 of the Outcome findings (above) but gave the matter further consideration. The panel were satisfied it was operational dishonesty for the following reasons:
82. The panel again reminded itself that the proper approach to cases involving operational dishonesty, derived from the case of Salter can be summarised as follows:
83. Following an application of aggravating factors and mitigating factors the Panel found their starting point of seriousness was unchanged and remained High.
Personal Mitigation
84. Having considered submissions from both parties on outcome, the panel then went on to consider the personal mitigation submitted on behalf of the officer in the form of (unblemished) service record for the officer and a number of character references.
85. Given the purpose of police misconduct proceedings, the panel kept in mind the fact that personal mitigation will carry limited weight and less than it might do in a different context [as explained by Holroyde J as he then was in The Queen (on the application of Williams) v Police Appeals Tribunal [2016] EWHC 2708 (QB)].
86. The panel also considered paragraph 7.5 of the guidance that states that less weight can be attached to personal mitigation where serious misconduct has been proven.
Character Evidence
87. The panel noted the evidence before it of the DS Hogg’s good character and noted that such evidence was potentially relevant to his credibility as a witness and to his propensity to behave in the way alleged, per Collins J in Wisson v Health Professions Council [2013] EWHC 1036 (Admin) at [44]: “As it seems to me, good character must always be likely to be relevant for the panel where there is a substantial issue of fact to be decided and where credibility of the registrant in the evidence that he gives, is an issue and it can also go to whether it is likely that he did what is alleged against him. Both aspects were prima facie material in relation to the findings that the panel had to make and the circumstances of this case.”
88. The panel reminded itself of para 3.12 of the guidance regarding the available outcomes at a misconduct hearing which are:
89. The panel is reminded at 2.6 of that guidance “In determining the appropriate outcome to impose, have regard to the principle of proportionality, weighing the interests of the public with those of the officer”
90. At 2.8 of that guidance, the panel is directed “consider less severe outcomes before more severe outcomes. Always choose the least severe outcome that deals adequately with the issues identified, while protecting the public interest.
91. The panel considered the less serious sanction first. The panel concluded that a written warning, final written warning, or reduction in rank would not be sufficient in this case, given the seriousness of the misconduct. The Panel also considered the need to maintain public confidence in the police service, uphold professional standards, deter future misconduct, and protect the public.
92. In all the circumstances and having considered submissions from both parties, the panel decided that the only appropriate and proportionate outcome for DS Hogg was dismissal without notice.
Barred List Information
93. The Chair has considered the relevant provision under the Police Barred List and Advisory List Regulations 2017 (“the 2017 Regulations”) and is satisfied that a report containing details of this case (in accordance with Regulation 3 of the 2017 Regulations) should be sent to the College of Policing within 5 working days. This is because there is no reason to depart from the general principle in this case.
Right of Appeal
94. The officers will be notified that they have a right of appeal to the Police Appeals Tribunal. The A/A will provide a notice to the officers as to the procedure to be followed in that regard.
ACC Alastair Simpson
Chair of Misconduct Hearing
Date: 24/08/2026