David Lloyd, counsel assisting the Royal Commission into Institutional Responses to Child Sexual Abuse, has recommended several adverse findings be made against John Lewis and Nicholas Sampson.
Mr Lewis was headmaster at Geelong Grammar School between 1980 and 1994 and went on to become headmaster at the prestigious Eton College in England.
Mr Sampson was headmaster from 2001 until 2004 and is currently the headmaster at Sydney's exclusive Cranbrook School.
Both men have been criticised for their handling of abuse allegations made against former teacher Jonathan Harvey.
In 2007, Harvey was jailed for 10 months for abusing a Geelong Grammar School student between 1976 and 1978.
The royal commission heard Mr Lewis was told of Harvey's abuse in 1982 and 1986 and was aware of additional complaints about Harvey's behaviour with students in 1991, yet allowed him unsupervised access to students.
The submission states: "Mr Lewis did not treat the issue of child sex abuse seriously and preferred the reputation of the school to the interests and welfare of students."
"If Mr Lewis had investigated allegations of child sex abuse that came to his attention, it is likely that a number of students at Geelong Grammar who were abused would not have been abused," the submission reads.
When giving evidence to the royal commission in 2015, Mr Lewis said: "I very much regret ... that I did not more fully satisfy myself at the time ... that the matter had been properly handled."
Mr Lewis's own submission to the royal commission said his ability to answer questions when giving evidence was compromised because he was not given adequate notice.
Teacher remained at school despite allegations
Counsel assisting's recommended findings have been published after an extensive investigation into the handling of abuse allegations by Geelong Grammar School.
Mr Lloyd is also critical of Mr Sampson for allowing Harvey to continue teaching after he was made aware of abuse allegations.
"Mr Sampson ought to have notified the Victorian Institute of Teaching of the allegations made against Mr Harvey and failed to do so," the submission stated.
"He failed to act in the best interests of of the students under his care at Geelong Grammar."
The submission is also critical of Mr Sampson's handling of Harvey's retirement from the school in 2005.
"Mr Sampson wrote letters to Mr Harvey that were misleading in that they omitted details as to the true reasons for Mr Harvey's departure from the school and in doing so failed to have regard for the interests of the students of any school at which Mr Harvey may teach," he said.
When giving evidence before the commission last year, Mr Sampson said: "I personally regret some of the things I did and I certainly wouldn't do them again."
Last year, the Cranbrook School council wrote to parents stating Mr Sampson continued to have the school's full support.
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