A Wairarapa teacher has been censured after holding the head of a student who was trying to push another student's head into a desk.
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The incident happened more than two years ago at Wairarapa College, where Lesley Davies had taught for more than 10 years.
Ms Davies told the tribunal she did not see her actions as physical abuse and she only wanted to prevent harm against another student.
She said there was no element of anger or aggression in her action.
But the Education Council's Disciplinary Tribunal said while they did not find her actions amounted to physical abuse they were still considered serious misconduct.
"We do find that pushing a student's head in these circumstances is an act that is likely to bring discredit to the profession. Therefore the test for serious misconduct is met," the tribunal said.
As well as the censure, it ordered her to undertake professional development in classroom management.
The president of the Post Primary Teachers' Association, Jack Boyle, said the case brought the wider issue of restraint in schools back into the spotlight.
Last month a teacher who carried a struggling child to a school principal's office was found guilty of misconduct despite the Teachers Disciplinary Tribunal admitting he was in a difficult position.
He said a law change earlier this year had not been followed up with adequate training for teachers and many were unsure what was allowed.
"The missing part is that if there are going to be changes to the way that that law is enforced and it's going to have a knock on effect to teachers' employment then surely professional learning so that teacher's know how to intervene safety would follow on and it just doesn't seem to have yet."
He said most teachers exercised good judgement about when an event required them to step in, but many were not sure how they could now go about doing that.
"I think the judgement's always been there. I'd go out on a limb here and say not every teacher in New Zealand has had training about how to intervene safely, it was just assumed that as your role in the classroom might cause you to jump in safely, when somebody's creating harm or there is a risk of harm, it's how do you do that safely you need the training, rather than the judgement."
Since the law change more than 400 reports have been lodged of teachers using physical restraint.