There aren’t many prosecutions for breach of the Human Medicines Regulations (see our Members’ article of 14 July 2025). What’s more, each case depends on its own particular facts, but a recent case was even described by the Court of Appeal as “interesting”.
In Mohammad Alazawi v Rex [2026] EWCA Crim 947, the defendant performed circumcisions at the request of parents of mainly Muslim babies and children. The circumcisions were performed for religious reasons rather than any medical need. The defendant was not medically qualified. He provided a mobile service, travelling to the family home of the young child, carrying out the procedure there. It is a procedure that is prevalent in Islamic culture, as it is in Judaism and some Orthodox Christian cultures. Where it is carried out for non-therapeutic reasons, it does not have to be carried out by a medical practitioner, and it is an unregulated practice. The law permits the circumcision of boys for a non-medical reason to be carried out as a lawful exception to the rule that one human being may not assault or injure another.
At the commencement of the circumcision procedure the defendant, having described the procedure to the parents and obtained their consent, would inject local anaesthetic in two places at the base of the child’s penis. When the anaesthetic took effect, he would continue with the circumcision.
At his trial at Southwark Crown Court in February 2025, the Defendant pleaded guilty to fifteen offences of parenteral administration of a prescription only medicine, contrary to regulation 214(2) and regulation 255(1)(b) of the Human Medicines Regulations 2012 . At the same time, he also pleaded guilty to three offences of supply of a prescription only medicine, contrary to regulation 214(1) and regulation 255(1)(a) of the Human Medicines Regulations 2012 , and two offences of supply of a pharmacy medicine, contrary to regulation 220(1) and regulation 255(1)(c) of the Human Medicines Regulations 2012 .
For the Human Medicines Regulations offences, the defendant was sentenced to 18 months imprisonment for each of the offences of parenteral administration of prescription medicines, concurrent with each other. He received concurrent sentences of between 12 months and 2 years for the remaining offences of supply of medicines.
The sentences should be seen in the context of the rest of the case because, after the guilty pleas, the trial continued on other charges, at the conclusion of which, the defendant was found guilty of 20 offences including six counts of fraud, seven counts of wounding with intent and one count of assault occasioning actual bodily harm. The fraud charges related to the defendant leading parents to believe he was medically qualified, which nullified their consent; and the wounding and assault charges related to the defendant’s poor standards (including poor hygiene) in carrying out circumcisions. No child suffered long-term harm.
Including the sentences for breaches of the Human Medicines Regulations, the trial judge sentenced the defendant to terms of imprisonment totalling 9 years.
The Court of Appeal decided that the totality of the sentences was excessive because some of the individual sentences were consecutive. The Court of Appeal held that administration of the local anaesthetics and the giving of aftercare medication were part and parcel of one overall circumcision procedure. The sentences for the breaches of the Human Medicines Regulations were not held to be wrong, but they should have been viewed as an aggravating feature of the principal charges so that the sentences should have been concurrent with other sentences rather than consecutive. The totality of the prison term was reduced to 6 years.
Below, Zubaran’s The Circumcision.
