Miss Neelam Dosanjh

Profession: Practitioner psychologist

Registration Number: PYL03721

Hearing Type: Final Hearing

Date and Time of hearing: 10:00 21/03/2019 End: 17:00 22/03/2019

Location: Health and Care Professions Tribunal Service, 405 Kennington Road, London, SE11 4PT

Panel: Conduct and Competence Committee
Outcome: Suspended

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Allegation

(As amended at the Final Hearing commencing 5 November 2019).

While registered as a Practitioner Psychologist with the Health and Care Professions Council, you:

1. Used the title of Doctor and / or allowed yourself to be described with the title of Doctor when you do not have the qualifications to do so:

a. On or around 13 September 2011, in an e-mail to colleagues;

b. On or around 05 December 2011, in a letter;

c. On or around 28 May 2012, in an e-mail to a colleague;

d. On or around 09 November 2012, in an article titled 'When Mentalisation Breaks Down: Suicide, Self-harm and Violence';

e. In that you co-authored a report entitled 'The Case For a Charter For Psychological Wellbeing and Resilience in the NHS' in or around 2015;

2. Your actions at Paragraphs 1(a) – (e) were dishonest.

3. The matters set out in Paragraph 1 (a) – (e) and Paragraph 2 constitute misconduct.

4. By reason of your misconduct, your fitness to practise is impaired.

 

Finding

Preliminary Matters

Application to Amend the Allegation

1. In the Notice of Allegation sent to the Registrant on 10 April 2018 it was outlined that amendments to the Allegation would be sought on the first day of the hearing to remove Particular 1(f) and to include a new Particular 2 which reads, “Your actions at paragraphs 1(a) to (e) were dishonest”. It was outlined that Particular 2 would now become Particular 3 and read “The matters set out in Paragraphs 1(a) – (e) and Paragraph 2 constitute misconduct”. It was also proposed that a duplicate of what is now charge 4 relating to impairment was removed. Ms Hastie on behalf of the HCPC applied to amend the particulars of the allegation as set out above.

2. Mr Milner on behalf of the Registrant did not oppose this application. In addition, he clarified that the allegation of dishonesty had been notified to the Registrant in good time and there was no formal application necessary to include this charge as it was part of the HCPC’s case against the Registrant as confirmed by the Investigating Panel.

3. The Panel was mindful of the issues of fairness and the avoidance of prejudice. The Panel considered that it was fair to allow the application to offer no evidence in respect of Particular 1(f) and accepted that the allegation of dishonesty had been properly notified to the Registrant to enable her to present her case.

Hearing in Private

4. At the outset of the Registrant’s evidence Mr Milner requested that the matters relating to the Registrant’s health and personal life should be heard in private. The Panel granted that application in view of the principles set out in the HCPTS Practice Note, “Conducting Hearings in Private”. The Panel determined that those parts of the hearing that concern the Registrant’s health and personal life should be conducted in private.


Background

5. The Registrant is a Clinical Psychologist. She completed an MSc in Clinical Psychology in 1992. She was later admitted as a Chartered Psychologist after a successful period of supervised professional practice. In 2014, East London Foundation Trust (the Trust) concluded an internal investigation into an allegation that the Registrant was using the title “doctor” without the necessary qualifications. That allegation was upheld and the Registrant was given a final written warning to remain on her file for 18 months.

6. In 2016, the HCPC received an anonymous complaint alleging that the Registrant had used the title ‘doctor’ repeatedly since 2007 without the necessary qualifications.

7. Following an investigation, the HCPC identified a number of documents and publications in which it is alleged that the Registrant dishonestly used the title ‘doctor’ or allowed herself to be described as such. The publications and documents are set out in the Allegation at Particulars 1(a) to (e).

8. At the outset of the hearing the Registrant admitted the factual elements of allegations 1(a) to (e) in so far as the title of ‘doctor’ was used. However, she did not accept she had allowed herself to be described as ‘doctor’. The Registrant did not admit that she had been dishonest.


Decision on Facts

9. On behalf of the HCPC the Panel heard live evidence from:

• KC - who chaired the 2014 Trust investigation;

• JV – a retired Membership and Governance Manager of the British Psychological Society (BPS);

• DT – Clinic Manager at the Registrant’s current place of employment; and

• AR – the co-author of the 2015 paper and professional colleague of the Registrant.

10. The Panel was provided with a bundle of documents from the HCPC and an additional witness statement from JV.

11. On behalf of the Registrant the Panel heard live evidence from her and was provided with a bundle of documents.

12. The Panel heard and accepted the advice of the Legal Assessor. In respect of the disputed facts, the Panel understood that the burden of proving each individual fact is on the HCPC and that the HCPC will only be able to prove a particular fact if it satisfies the required standard of proof: namely the civil standard, whereby it is more likely than not that the alleged incident occurred. The Panel accepted the advice of the Legal Assessor in relation to the test for dishonesty as outlined in the case of Ivey v Genting Casinos (UK) Ltd [2017] UKSC67.

13. The Panel considered the evidence of all of the witnesses. It considered the evidence of KC to be straightforward and he was able to give a clear account of the matters relating to the Trust procedure in 2014. The Panel accepted his evidence but was mindful that it was required to make its own decisions on the evidence.

14. The Panel considered the evidence of JV. She gave evidence regarding the processes in place at the British Psychological Society (BPS) at the relevant time. The Panel considered that she was a helpful and credible witness with extensive experience. The Panel accepted the evidence she gave.

15. The Panel considered the evidence of DT to be clear and straightforward and accepted her evidence regarding her assessment of the character of the Registrant. The Panel also accepted her evidence that, in her experience, the Registrant had taken steps to correct the use of the title ‘doctor’.

16. The Panel found AR to be a credible and helpful witness. The Panel considered that she was fair in her evidence and gave a balanced account. The Panel noted that she was firm in her recollection of events and consistent in her oral evidence to the Panel and her witness statement.

17. The Panel considered that the Registrant was evasive in her evidence at times and the evidence she gave was not consistent with other documentary evidence in the bundle in some material respects. The Panel accepted that the Registrant was under some stress during her evidence. However, the Panel considered that the Registrant’s recollection of certain events was unreliable and contradictory.

Particulars 1(a) to (d) – Found Proved

1. Used the title of Doctor and/or allowed yourself to be described with the title of doctor when you do not have the qualifications to do so:

a. On or around 13 September 2011 in an email to colleagues;

b. On or around 05 December 2011, in a letter;

c. On or around 28 May 2012, in an email to a colleague;

d. On or around 09 November 2012, in an article titled ‘When Mentalisation Breaks down: Suicide, Self-harm and Violence’

18. The Panel had regard to the admissions made by the Registrant that she had in fact used that title for the documents covered in Particulars 1(a) to (d). It was a matter of fact that the Registrant had used the title and it was accepted that the Registrant did not have the necessary qualifications to use that title. The Panel did not consider it was necessary or appropriate to make a further finding that the Registrant had allowed herself to be described with that title.

Particular 1(e) – Found Proved

e. In that you co-authored a report entitled ‘The Case For a Charter For Psychological Wellbeing and Resilience in the NHS’ in or around 2015;

19. At the time that this paper was drafted the Registrant was aware that she did not have the qualification and should not be using the title ‘doctor’.

20. AR gave evidence that the paper was circulated in draft format on a number of occasions for the authors (including the Registrant) to comment upon and amend if necessary. AR was clear, both in her witness statement and in her oral evidence that the whole of the paper, including the biography details and order of authorship on the front page would have been provided to the Registrant before the paper was finalised. The Panel considered this was credible and likely to have happened in the way AR described for a paper of this nature. AR was clear that it had never been brought to her attention by the Registrant that the title used in the paper was incorrect and should be removed. AR said in her evidence that she was never made aware by the Registrant that she was not qualified to use the title ‘doctor’ and only discovered this fact after the HCPC contacted her as part of this investigation. She gave evidence that during her first year of knowing her, the Registrant had told her that she had completed a PhD before qualifying as a Clinical Psychologist and had thereby acquired the ‘doctor’ title. AR said that she had no reason to doubt what the Registrant had told her.

21. The Panel did not accept the Registrant’s evidence that she had not seen the front sheet of the paper or the biography before it was finalised and published at the conference. The Panel does not consider it likely that a paper such as this, where the qualifications of the authors and order of authorship were considered to be important factors, would not be included in the circulated drafts for checking and approval. The Panel took account of the Registrant’s email in December 2015 which stated “no title” but did not consider that this explicitly addressed the issue of the authorship or pointed out to anyone editing the paper that she had been incorrectly described.

22. The Panel concluded that the reason the title came to be used was because the Registrant had not taken any action to point out to anyone that it was incorrect. The Panel was satisfied that the Registrant knew the title had been used in the drafts and allowed it to proceed to publication without correction.

Particular 2 – Found proved

2. Your actions at paragraphs 1(a) to (e) were dishonest.

In relation to Particulars 1(a) to (d)

23. The Panel considered that the Registrant’s evidence about why she thought she was entitled to use the title doctor in around 2007 lacked credibility. The Panel accepted the evidence of JV that there was no process in place as described by the Registrant whereby research could be evaluated and a doctorate awarded by the BPS. JV was clear that there were “top-up” doctorates available at universities. She explained that Chartered Status was benchmarked at doctorate standard but did not confer the title ‘doctor’. However, the BPS could not and did not award doctorates or accredit research as a “top-up” project to a master’s qualification.

24. JV said that she had no knowledge of the letter written in 2006 by the Registrant. Although all paper records have now been destroyed the letter appears never to have been replied to. JV went on to say that it was likely that had such a letter been received by the BPS it would have been the subject of a bespoke reply. JV also said that any advice allegedly given to the Registrant that the BPS was able to do what the she had asked for in her letter was either incorrect or misunderstood.

25. JV said that at the time the letter was written there was no membership team and this came about as a result of a restructure in 2007. JV said that it was unlikely anyone outside the BPS would have known about this restructure in December 2006 as it was only out for consultation and was not implemented until the third quarter of 2007.

26. The Registrant said in her oral evidence that the person she spoke to on the telephone at the BPS in late 2006 told her to write to the Membership Team because that would be the new department that would deal with her query. The Panel considered that this was very unlikely and preferred the evidence of JV.

27. The Panel could not be satisfied that the letter had even been sent or received. The Registrant was vague and inconsistent in her recollection of how she came to retrieve, for the Trust investigation in 2013, a copy of the letter she had written in 2006. There was no response from the BPS and no follow up from the Registrant. JV could not recall receiving the letter. She said that at the time she was working in the Admissions Team and in her then managerial role it was likely that she would have been made aware of it. The Registrant’s HR department did not have a copy of the letter either despite being copied in. There was no correspondence from the BPS on the Registrant’s HR file. The Registrant initially said that she had photocopied the letter that was sent to the BPS. Later in her evidence she said that it was not a photocopy and that she had printed it out at the time from the hard drive of her personal computer using a family member’s printer. Although the letter stated it was copied to the Registrant’s HR department it was not found on her HR file.

28. The Registrant said in her oral evidence that she did not expect the BPS to award her the doctorate and she understood that it would be awarded either by the University of East London or sent to another University. This is at odds with her written response to the Trust investigation in which she states, “I had investigated with the BPS that I could apply to them under a special case, for review of previous research as an equivalent to a top up. I was informed by them that those applying for a doctorate status applied by providing the BPS with notification of achieving a doctorate level in the top up research project.” Later in her response she states, “…two things happened in 2007 which made me assume that the BPS had approved my status in a straightforward way”.

29. The Panel considered the academic background of the Registrant and noted that she was not unfamiliar with academic research and the procedure for the “top-up” doctorates to the MSc in Clinical Psychology. The Panel accepted the Registrant’s evidence that, in her mind, the research she had undertaken was at a higher level than the research undertaken by others who had completed a “top-up”. The Panel also accepted that there had been conversations with the Registrant’s then line manager, EB, about the process. However, the Panel considered the Registrant’s explanation of the route she had allegedly taken via the BPS that she claimed would lead to an award of the title ‘doctor’ lacked credibility and was wholly implausible.

30. Taking into account all of the evidence the Panel preferred the evidence of JV and was not satisfied that the Registrant had received advice from the BPS that she could achieve doctorate status by writing a letter with details of her research project.

31. Despite the Registrant stating that she had had a conversation with AH from HR who allegedly confirmed that she had seen “something from the BPS” no letter from the BPS was ever received. During the Trust investigation AH confirmed that she could not recall any conversation with the Registrant relating to her application to the BPS nor any correspondence from them. She said that she would have remembered if she did have such a conversation. She said that the type of application would be the responsibility of the member of staff and would not normally require HR involvement.

32. The Panel did not consider it was credible that the Registrant forgot or was too distracted to follow up such a conversation by requesting a copy of the document before using the title. The Registrant had received no documentation of any kind to support her alleged belief that she had been awarded a doctorate as a result of the one letter she sent in 2006.

33. In May 2007, the Registrant is described as ‘doctor’ in minutes of a meeting she attended. There is no evidence before the Panel that the Registrant questioned or corrected the use of the title and there is no evidence to support her view that the title was used independently by the Department of Health. Further, a letter from the Trust sent to the Registrant in 2008 using the title doctor was not, in the Panel’s view, credible evidence to support a belief that the HR department had confirmed she was able to use the title.

34. The Panel did not accept the Registrant’s evidence about when the title came to be used as it was inconsistent and vague. The Panel concluded that it was more likely that the Registrant had started using the title herself without checking after she had been incorrectly described as ‘doctor’ in the minutes of a meeting in May 2007.

35. The Panel accepted that the Registrant was under stress at the time. The Panel also accepted that the Registrant is a competent and committed clinician who is well respected. It was submitted that the Registrant made gross errors because of administrative oversights given her workload and stress. The Panel noted that there was no evidence that the Registrant was considered to be otherwise lacking in her administrative skills at this time. On the contrary, she successfully steered the service she was responsible for through a period of significant change. The Panel did not accept these to be persuasive reasons why the Registrant did not take straightforward and easy steps to find out the true position with regard to the sudden use of the title.

36. The Panel had regard to the Registrant’s oral evidence in which she stated that the title was not important to her and it brought her no enhanced work or remuneration. The Panel noted that the Registrant said she was embarrassed and ashamed to tell AR that she was not able to use the title and had not been able to have that conversation with her. Indeed, she did not tell AR until the HCPC had approached the witness in 2017 and it was AR who raised the matter with the Registrant. The Registrant said she had felt unable to tell any colleagues other than AR. In addition, the Registrant stated that she had used the title because it gave her equivalence with her peers who had either qualified just after her and obtained the title or undertaken “top-ups”. The Panel concluded that the title was important to the Registrant and that she was aware of the status it brought her with others. The Panel considered that the Registrant was motivated by the cachet of the title believing that it would assist her given the difficult negotiations and meetings in which she was involved with senior representatives of other Trusts and the Department of Health regarding her department.

37. Taking account of all the evidence, the Panel concluded that the Registrant could not have genuinely believed that she had been given doctorate status in 2007. The Panel concluded that her use of the title when she knew she did not have the qualifications to support it was dishonest by the standards of ordinary decent people.

In relation to Particular (e)

38. The Panel has already found that the Registrant allowed herself to be described as doctor because she did not take any steps to correct the use of the title. The Panel considered that this failure to correct the paper was a deliberate and dishonest act on the part of the Registrant because she was ashamed and embarrassed to admit to AR that she was not able to use the title. The Panel determined that this would be considered dishonest by the standards of ordinary decent people.


Adjournment of Proceedings (9 November 2018)

39. Following its decision on facts the Panel announced that the proceedings would have to adjourn part-heard due to a lack of time to consider the grounds and impairment stages. The hearing will reconvene over two dates on 21 to 22 March 2019.


Reconvened Hearing 21 to 22 March 2019


Decision on Misconduct

40. The Panel then considered whether the facts found proved amounted to misconduct. Misconduct must be serious. The Panel has made findings in relation to the Registrant dishonestly using the title of doctor in a range of different professional circumstances. This persisted over a significant period of time. The Panel had heard evidence that other professionals were misled about the true position and it considered it was likely that members of the public would have been similarly misled. The Panel considered that the Registrant’s dishonest conduct fell far short of the standards expected of a registered professional.

41. The Panel notes the HCPC “Standards of conduct, performance and ethics” 2008 to 2016 and in particular Standard 3 “You must keep high standards of personal conduct.” and Standard 13 “You must behave with honesty and integrity and make sure that your behaviour does not damage the public’s confidence in you or your profession.”

42. The Panel considered that the reputation of psychologists was damaged by the Registrant’s conduct and individuals were misled. The Registrant’s conduct had the potential to devalue the title for others.

43. The Panel considered that these failings would be considered deplorable by fellow practitioners and individually and cumulatively amounted to misconduct.


Decision on Impairment

44. The Panel went on to consider the issue of impairment by reason of the Registrant's misconduct. It had careful regard to all the evidence before it and to the submissions of Ms Hastie for the HCPC and Mr Milner on behalf of the Registrant. It accepted the advice of the Legal Assessor and had particular regard to the HCPTS Practice Note on “Finding that Fitness to Practise is ‘Impaired’”.

45. The Panel first considered past impairment. It noted its findings that the Registrant had deliberately and dishonestly used the title of doctor. It had also found that the Registrant’s misconduct had breached key standards of the HCPC’s “Standards of conduct, performance and ethics” as set out above, had brought the profession into disrepute and had undermined confidence in the profession. In addition, the Registrant’s misconduct had the potential to mislead patients and risked damaging the therapeutic relationship if they subsequently discovered that she did not have the qualifications that would allow her to call herself ‘doctor’.

46. The Panel went on to consider whether the Registrant’s fitness to practise is currently impaired by reason of that misconduct. In addressing the personal component of impairment, the Panel asked itself whether the Registrant is liable, now and in the future, to repeat misconduct of the kind found proved. In reaching its decision, the Panel had particular regard to the issues of insight and remediation.

47. The Panel noted that in the case of CHRE v NMC & Grant [2011] EWHC 927 (Admin) Mrs Justice Cox stated: “When considering whether or not fitness to practise is currently impaired, the level of insight shown by the practitioner is central to a proper determination of that issue.”

48. The Registrant has submitted a further bundle of documents including a reflective piece and testimonials and she gave live evidence before the Panel at facts stage where she expressed remorse.

49. In the Panel’s view the Registrant has demonstrated only limited insight into the seriousness of her misconduct and its impact on colleagues, patients and the profession. The Panel was concerned that the Registrant did not seem to fully appreciate her culpability for the seriousness of her failings and sought to minimise her responsibility.

50. The Panel had careful regard to Silber J’s guidance in Cohen v GMC [2008] EWHC 581 (Admin) that Panels should take account of:

• Whether the conduct which led to the charge is easily remediable;

• Whether it has been remedied; and

• Whether it is highly unlikely to be repeated.

51. The Panel recognised that remediation of misconduct which involves dishonesty may be less easy than remediation of misconduct involving clinical failings. The Panel accepted the evidence that the Registrant is a good clinical practitioner. It considered that she has yet to develop with more meaningful insight required to prevent repetition. It noted the Registrant’s assurances that she has learned from this experience and her psychological reflection as to the reasons why it arose. However, she does not appear to have understood the potential impact of her behaviour on colleagues, patients and the profession.

52. The Panel also noted that the Registrant has continued to work as a Psychologist since the incidents in question, and that there has been no repetition. However, the Panel received no evidence of any specific relevant remediation which the Registrant may have undertaken such as courses on professional ethics or any steps that the Registrant has taken to advise other professionals that she is not able to use the title. The Panel was not persuaded that the Registrant had overcome her embarrassment to enable her to be open and honest with other professionals about her circumstances.

53. In light of its findings in relation to insight and remediation, the Panel considered that there is currently a risk that the Registrant would repeat matters of the kind found proved. For these reasons, the Panel determined that a finding of impairment is required with regard to the personal component, including the need for public protection.

54. The Panel then went on to consider whether a finding of impairment is necessary on public interest grounds. In addressing this component of impairment, the Panel had careful regard to the critically important public issues identified by Silber J in the case of Cohen when he said:

“Any approach to the issue of whether .... fitness to practise should be regarded as ‘impaired’ must take account of…the collective need to maintain confidence in the profession as well as declaring and upholding proper standards of conduct and behaviour.”

55. The Panel considered that honesty and integrity is a cornerstone of the profession. The Panel considered that the public would be concerned to learn of the Registrant’s dishonesty in this matter. Further, the Panel had no doubt that the need to maintain public confidence in the profession, and to declare and uphold proper standards, would be undermined if a finding of impairment of fitness to practise was not made in the circumstances of this case in relation to the Registrant’s dishonesty.

56. For all the reasons set out above, the Panel determined that the Registrant’s fitness to practise is currently impaired, both on the grounds of public protection and in the public interest.


Decision on Sanction

57. Having determined that the Registrant’s fitness to practise is currently impaired by reason of her misconduct, the Panel next went on to consider whether it was impaired to a degree which required action to be taken on her registration by way of the imposition of a sanction.

58. At this stage the Panel heard evidence from Dr GB, the Registrant’s current employer. The Panel also heard evidence from EB, the Registrant’s former line manager and clinical supervisor. The Registrant’s husband gave evidence about the impact that the proceedings have had and the Registrant’s character.

59. The Panel had regard to all of the evidence in the case and the submissions made by Ms Hastie on behalf of the HCPC and Mr Milner on behalf of the Registrant.

60. The Panel accepted the advice of the Legal Assessor and exercised its independent judgement. The Panel had regard to the HCPC’s “Indicative Sanctions Policy” and considered the sanctions in ascending order of severity. The Panel was aware that the purpose of a sanction is not to be punitive but to protect members of the public and to safeguard the wider public interest, which includes upholding standards within the profession, together with maintaining public confidence in the profession and its regulatory process.

61. The Panel first identified what it considered to be the principal aggravating and mitigating factors in this case.

Aggravating factors:

• The Registrant‘s dishonesty persisted over a significant period of time in a range of circumstances.

Mitigating factors:

• The Registrant has had a lengthy professional career at a senior level, and there have been no previous regulatory concerns;

• The references and evidence provided to the Panel attested positively to the Registrant’s usual honesty and integrity and her commitment to her practice and her patients; and

• The Registrant has engaged with the HCPC throughout this process.

62. The Panel had heard further evidence from the witnesses about the Registrant’s level of insight. However, when considering all of the evidence adduced in the case and looking particularly at the Registrant’s reflective statement, the Panel considered that the Registrant had not fully developed her insight for the Panel to be satisfied that there was a low risk of repetition of acts of dishonesty. The Panel considered that the Registrant had not fully taken responsibility for her conduct and, in the Panel’s view, was still seeking to blame external factors.

63. The Panel considered the sanctions available, beginning with the least restrictive. The Panel did not consider the options of taking no further action, mediation, or the sanction of a Caution Order to be appropriate or proportionate in the circumstances of this case. In view of the limited insight demonstrated by the Registrant, none of these options would address the consequent risk of repetition which the Panel had previously identified nor would they reflect the seriousness of the case.

64. The Panel next considered the imposition of a Conditions of Practice Order. The Panel was satisfied that this case did not raise any clinical concerns which may be appropriately addressed through conditions. The Panel was of the view that it was not possible to formulate workable or practicable conditions which would address the Registrant’s dishonesty. Further, the Panel considered that the case was too serious for a Conditions of Practice Order.

65. The Panel next considered a Suspension Order and concluded that this was the appropriate and proportionate sanction in the circumstances of this case. Although the Panel had found that the Registrant’s insight was limited at this time, it considered that a Suspension Order would provide a further opportunity to the Registrant to reflect on her misconduct and to demonstrate that she had developed an appropriate level of insight. The Panel also considered that such an order is required to maintain public confidence in the profession and to uphold professional standards.

66. The Panel considered that the length of the order should be for 6 months. This is with a view to the Registrant demonstrating to the next Panel that she has reflected on her actions, taken responsibility for them, and has developed sufficient insight into them. The Panel also considered that public confidence in the profession would be damaged if any lesser period were imposed.

67. The Panel acknowledged that the “Indicative Sanctions Policy” lists dishonesty as the type of case in which a Striking Off Order may be appropriate. However, in the context of the Registrant’s lengthy career, the Panel was of the view that a Striking Off Order would be unduly punitive. The dishonesty, while serious, was not at the most serious end of the scale, and the Registrant had taken some steps to address her misconduct. In light of this and given that the Panel has found that the Registrant may be able to develop further insight over the course of a Suspension Order, the Panel is of the view that a Striking Off Order would be disproportionate at this time.

68. This Panel does not seek to fetter the discretion of a future reviewing panel, but it considers that such a Panel may be assisted by any information which evidences a developed level of insight. This might include learning from a face to face course targeted towards professional ethics. This Panel considers that a future panel would be further assisted by a reflection from the Registrant which demonstrates her learning from any courses she has undertaken. This Panel considers that a future panel may be assisted by the Registrant demonstrating her understanding of the impact her dishonesty may have had on others and on public confidence in the profession and how she would avoid a repetition of her dishonesty in the future.

69. The Panel acknowledges that such an order will have an adverse impact upon the Registrant both personally and professionally. However, the Panel determined that the interests of protecting the public and maintaining public confidence in the profession outweigh the interests of the Registrant.

Order

The Registrar is directed to suspend the registration of Miss Neelam Dosanjh for a period of 6 months from the date this Order comes into effect.

Notes

Interim Order

1. There has been an application by the HCPC for an interim order to cover the appeal period. Mr Milner on behalf of the Registrant did not oppose the making of an interim order.

2. The HCPC’s application is made on the two statutory grounds as follows:

• it is necessary for the protection of members of the public; and

• is otherwise in the public interest.

3. The Panel makes an Interim Suspension Order under Article 31(2) of the Health and Social Work Professions Order 2001, the same being necessary to protect members of the public and being otherwise in the public interest. The Panel considered that to do otherwise would be inconsistent with its earlier findings and would not protect the public against the risk of repetition of the misconduct.

4. This Interim Order will expire, if no appeal is made against the Panel’s decision, upon the expiry of the period during which such an appeal could be made. If an appeal is made against the Panel’s decision this Interim Order will expire on the final determination of that appeal, subject to a maximum period of 18 months to cover the length of any appeal.

Hearing History

History of Hearings for Miss Neelam Dosanjh

Date Panel Hearing type Outcomes / Status
21/03/2019 Conduct and Competence Committee Final Hearing Suspended
05/11/2018 Conduct and Competence Committee Final Hearing Adjourned part heard