Appeals from Refusals to Grant a Certificate of Completion of Training (CCT)
General Medical Council v Nakhla  EWCA Civ 1522 – appeal allowed at Court of Appeal
Sanctions for Alleged Falsified Evidence Submitted in CESR & CEGPR Applications
Igwilo v the General Medical Council.  EWHC 419 (Admin) The doctor appealed an erasure order of a MPT, relating to falsified evidence submitted by way of a CESR application. The erasure order was upheld and the appeal was dismissed. One aggravating feature was noted, as follows (para 31, last bullet point):
“Dr Igwilo’s misconduct had the potential to cause harm to patients, in that, had his dishonesty not been recognised it could have resulted in his being granted a Certificate of Eligibility for Specialist Registration, which could have enabled him to obtain a substantive consultant position which he was not qualified or entitled to undertake.”
The dishonesty was considered to be significant. The court quoted another judge’s remarks that summarised the degree of dishonesty displayed by the doctor – taken from an earlier case that concerned the same doctor (see para 28)
“He falsified a large number of documents: 24 documents described as reports in respect of different patients, 5 documents described as reports for Courts or Tribunals in respect of different patients, 7 sets of documents described as section 48 paperwork for different patients, 1 set of documents described as section 37 paperwork, 4 referral letters, 2 letters to patients’ general medical practitioners and correspondence confirming appointments and placements and other correspondence. The scale of the falsification indicated it was an elaborate deception which must have taken some considerable time to plan and implement. His dishonesty affected his professional colleagues, as he represented their work as his own, or claimed that they had approved of his work when they had not done so.”
The moral of the story is to not submit falsified documents within a CESR application.