CITY OF DEATH

The obvious moment is in the last episode when the Doctor returns to the
cellar to find her working for Scaroth, and he says he'll be very angry
with her if she has been building a time machine (which of course she
has). So when they are locked up again with Duggan, the Doctor's first
action, after admonishing Romana and telling her (to her horror) that
she has been working for the Jagaroth, is to put her across his knee and
pull up her skirt to reveal those tight, cream panties I mentioned.
Duggan at once intervenes with his characteristic 'We don't have time
for this' routine. (I guess he takes the fact of the spanking for
granted: Romana's outfit establishes her as obviously the Doctor's pupil
and subject to his discipline. But he just wants to get out, and the
Doctor can deal with her later; but this would not be much good for us,
because that would have to be after the end of the story!) Anyways, from
her undignified position Romana fixes him with a look and says 'You keep
out of this', then grits her teeth as the Doctor's palm starts to crack
down hard across her under-protected bottom.

Another correspondent of mine (not on the mailing list, sadly) once
suggested that Romana could get caught up in a school trip to the Louvre
and punished by the schoolmistress. I'll have to look out that message.

For good measure, let's also have the Doctor giving the Countess a
spanking: she's such a naughty girl! (Somehow the business of stealing
the Mona Lisa for fun and kudos is on that level, unlike the considered
evil of Scaroth.) The best opportunity is when he confronts her, again
in the last episode: maybe a good spanking will cure her of her willful
blindness. Of course, the Countess would call for her servants to come
and intervene, but maybe they would be just a little slow once they
arrived - enjoying the spectacle too much!