Miss Aparna Srivastava
Please note that the decision can take up to 5 working days to be uploaded onto the HCPTS website. Please contact one of our Hearings Team Managers via tsteam@hcpts-uk.org or +44 (0)808 164 3084 if you require any further information.
Allegation
The allegation:
As a registered Dietitian (DT07126) your fitness to practise is impaired by reason of misconduct and/or lack of competence. In that:
1. While working as a locum Dietitian for City Health Care Partnership (CHCP) between 20 November 2017 and 9 February 2018, you did not:
a. Enter names and/or NHS number on records completed for patients listed in Schedule A
b. Record clinical reasoning and/or evidence base for food and drink recommended to patients in Schedule B.
c. Record clinical reasoning and/or evidence base for recommending chewing food 32 times to patients listed in Schedule C.
2. You recommended using specific shops and/ or brands to the patients listed in Schedule D, without providing clinical reasoning for doing so.
3. You recommended that Patient 69 listen to Classic FM “first thing in the morning and last thing at night” with no explanation or clinical reasoning for doing so.
4. ....
5. You recommended that Patient 128, who was 91 years old and suffering from Parkinson’s Disease, “try Sahaj Yoga” with no explanation or clinical reasoning for doing so.
6. You sent a Whatsapp message to Colleague A on 3 February 2018 stating words to the effect that:
a. cancer does not spread without sugar and will die on its own without sugar;
b. taking a full lime in warm water is 1000 times more effective than chemotherapy; and
c. taking three spoons of organic or virgin coconut oil in the early morning will keep cancer at bay.
7. The recommendations made at particular 6 (a), (b) and (c) were not clinically justified.
8. The matters set out in particulars 6 and 7 constitute misconduct.
9. The matters set out in particulars 1, 2, 3, 4 and 5 above constitute misconduct and/or a lack of competence.
10. By reason of your misconduct and/or lack of competence your fitness to practise is impaired.
Schedules
Schedule A
1. Patient 12
2. Patient 14
3. Patient 15
4. Patient 16
5. Patient 19
6. Patient 25
7. Patient 26
8. Patient 43
9. Patient 44
10. Patient 73 a
11. Patient 73 b
12. Patient 77
13. Patient 83
14. Patient 95
15. Patient 101
16. Patient 107
17. Patient 108
18. Patient 112
19. Patient 113
Schedule B
1. Patient 1
2. Patient 4
3. Patient 6
4. Patient 7
5. Patient 9
6. Patient 10
7. Patient 17
8. Patient 18
9. Patient 20
10. Patient 25
11. Patient 26
12. Patient 27
13. Patient 29
14. Patient 31
15. Patient 32
16. Patient 33
17. Patient 35
18. Patient 39
19. Patient 41
20. Patient 42
21. Patient 43 a
22. Patient 43 b
23. Patient 48
24. Patient 49
25. Patient 51
26. Patient 52
27. Patient 55
28. Patient 56
29. Patient 57
30. Patient 59
31. Patient 61
32. Patient 63
33. Patient 64
34. Patient 65
35. Patient 68
36. Patient 69
37. Patient 70
38. Patient 71
39. Patient 72
40. Patient 73
41. Patient 74
42. Patient 75
43. Patient 76
44. Patient 77
45. Patient 78
46. Patient 80
47. Patient 81
48. Patient 85
49. Patient 87
50. Patient 88
51. Patient 89
52. Patient 90
53. Patient 91
54. Patient 93
55. Patient 94
56. Patient 95
57. Patient 98
58. Patient 102
59. Patient 103
60. Patient 106
61. Patient 107
62. Patient 109
63. Patient 111
64. Patient 113
65. Patient 116
66. Patient 121
67. Patient 124
68. Patient 125
69. Patient 126
70. Patient 127
71. Patient 128
72. Patient 130
73. Patient 135
74. Patient 138
75. Patient 139
76. Patient 140
77. Patient 141
78. Patient 143
Schedule C
1. Patient 17
2. Patient 20
3. Patient 27
4. Patient 39
5. Patient 55
6. Patient 59
7. Patient 63
8. Patient 65
9. Patient 69
10. Patient 72
11. Patient 85
12. Patient 86
13. Patient 87
14. Patient 90
15. Patient 113
16. Patient 124
Schedule D
1. Patient 7
2. Patient 18
3. Patient 29
4. Patient 41
5. Patient 60
6. Patient 61
7. Patient 62
8. Patient 81
9. Patient 86
10. Patient 91
11. Patient 94
12. Patient 108
13. Patient 109
14. Patient 110
15. Patient 111
16. Patient 116
17. Patient 121
18. Patient 140
19. Patient 142
Finding
Preliminary Matters
1. The Panel has been convened to undertake the review of a substantive conditions of practice order imposed in respect of the registration of the Registrant, Miss Aparna Srivastava, a Dietitian. The review is being conducted under the provisions of Article 30(1) of the Health Professions Order 2001.
Service of the notice of hearing
2. On 16 July 2025, an email was sent to the Registrant and her Solicitors informing them of the date and time of the hearing, as well as the fact that the hearing would be conducted by Microsoft Teams. The Panel was satisfied that this communication constituted a valid notice of hearing.
Conducting the hearing partly in private
3. The Panel was requested to make a direction that parts of the hearing should be conducted in private. The same application was made to, and was granted by, the final hearing panel, and that panel produced a private version of its written determination. It would also be necessary for the Registrant’s health to be mentioned to deal with the issue of her engagement in the review process. The direction that the hearing should be conducted partly in private was necessary, it was submitted, to protect the Registrant’s private life.
4. Having taken the advice of the Legal Assessor, the Panel acceded to the application.
Proceeding in the absence of the Registrant
5. The Presenting Officer applied for a direction that the hearing should proceed in the Registrant’s absence.
6. Relevant to the Panel’s decision are the following:
• On 22 July 2025, a HCPC Case Manager wrote to the Registrant about this review, reminding her of the conditions that had been imposed. In response to this email, on 30 July 2025, the Registrant replied stating, “As of now, I will be attending my hearing on the 13th of August 2025. My lawyer is on annual leave at present. Will get back to you as soon as [my lawyer] gets back to me.”
• In a telephone conversation with the Case Manager on 31 July 2025, the Registrant referred to [Redacted].
• At 12:20pm on 12 August 2025, (i.e. less than 24 hours before the commencement of this hearing) the Registrant’s Solicitor sent an email, the body of which was in the following terms:
“Further to your email below [an email sent by the Hearings Officer on 8 August 2025 to both the Registrant and her Solicitor asking about attendance at the hearing] neither the registrant nor a representative will be attending this hearing. [Redacted]. It is now the registrants [sic] intention to apply for a voluntary remove [sic] [Redacted], the length of time away from practice, the retraining now required, and the lack of realistic opportunities for supervised practice, there is no viable route back into the profession at this stage.
The registrant has not been working and as such has not been able to comply with the conditions of her current order.
I would be grateful if you could please forward this email to the Panel.”
• The Registrant also sent an email on 12 August 2025, requesting that it should be placed before the Panel. “I must express my deep concern regarding the way the British Dietetic Association has handled this matter. [Redacted]. I do not believe it is reasonable for me to attend the hearing under these circumstances.”
7. The conclusion of the Panel is that the Registrant has voluntarily absented herself from this hearing. [Redacted]. Furthermore, the public interest requires a review of the Conditions of Practice Order to be undertaken before it expires, and quite apart from the logistical difficulties there would be in giving the required notice for, and finding a hearing date on, a hearing on or before 19 September 2025, there is no suggestion by the Registrant that she would attend a future hearing. The Panel notes that neither the Registrant nor her Representative had requested an adjournment. Accordingly, the clear public interest requires this hearing to proceed.
8. So far as the mention of voluntary removal in the email of 12 August 2025, is concerned, that is an issue over which the Panel has no jurisdiction. However, the Panel would expect it to be obvious that a request for voluntary removal would have to be made long in advance of a review hearing for it to have any bearing on whether that hearing should proceed.
Background
9. The Registrant was employed as a Locum Dietitian within the East Riding Community Dietitian team at City Health Care Partnership (“CHCP”) from November 2017 until February 2018. She worked with adult core dietetic patients. Her line manager was Colleague B.
10. Several weeks after the Registrant began working at CHCP Colleague C, noted that several colleagues were identifying concerns in relation to the treatment the Registrant had been providing to patients. Colleague C sent an email to colleagues on 5 March 2018 asking them to relay to her their concerns. These concerns were collated by Colleague C and sent to the HCPC with a completed referral form on 3 April 2018.
11. The HCPC’s Allegation reflected the concerns communicated by the CHCP.
12. The final hearing of the Allegation took place over nine hearing days between 10 January 2023, and 22 August 2023. The Registrant attended the hearing and was represented at it by Counsel. The Registrant made some limited admissions with regard to particular 1(a) of the Allegation, but otherwise denied the matters alleged against her.
13. The decision of the final hearing panel in relation to the factual particulars was as follows:
• Particular 1(a) was proven in relation to 15 service users, but not proven in relation to 3.
• Particular 1(b) was proven in relation to 67 service users, but not proven in relation to 9.
• Particular 1(c) was proven in respect of both clinical reasoning and an evidence base in all records save for two records (which had clinical reasoning)
• Particular 2 was proven with regard to 8 records in relation to recommendation for a brand, but not proven with regard to 3 records.
• Particular 3 was proven.
• Particular 4 was not proven.
• Particulars 5, 6 and 7 were proven.
14. When the Panel addressed the question of whether the proven facts constituted misconduct and/or lack of competence, its findings were that:
• Particular 1(a) amounted to misconduct. This finding was made on the basis that the breaches were not one-offs, but were repeated on many occasions. The breaches were also so serious and fell so far short of the standards expected of a practising Dietitian that the finding of misconduct was warranted.
• Lack of competence was demonstrated by particulars 1(b), 1(c), 2, 3 and 5.
• Particulars 6 and 7 did not contribute to the findings of either misconduct or lack of competence.
15. In relation to impairment of fitness to practise, the final hearing panel stated that despite being told of the panel’s findings of fact on 20 January 2023, and stating that she accepted them, the Registrant nevertheless demonstrated limited insight because she continued to minimise the seriousness of her conduct when giving further evidence before that panel on 12 July 2023. She failed to take personal responsibility for what occurred, instead attributing her failings to her working conditions. The Registrant had herself acknowledged that she would require further training before returning to practice. The final hearing panel agreed that further training was required, and stated that without it, there would be a risk that the misconduct and lack of competence would be repeated. For these reasons, the final hearing panel found that the Registrant’s fitness to practise was impaired in relation to the personal component. It also found that the public component of impairment of fitness to practise was engaged as the Registrant had not met required professional standards, she had placed service users at risk of harm and she had breached fundamental tenets of her profession.
16. The sanction determined upon was the Conditions of Practice Order imposed for a period of 2 years that the present Panel is currently reviewing. In explaining its reasons for imposing that Order, the final hearing panel stated this:
In assessing whether a Conditions of Practice Order is the proportionate and appropriate sanction, the Panel considered whether a short period of suspension would provide any further benefits to the public or the Registrant. The Panel came to the conclusion that this was not the case. The Public would gain no benefit from the Registrant being out of practice for a further period of time. The Registrant is able and willing to remediate her failings and a Conditions of Practice Order would facilitate this therefore a period of suspension would, in the Panel’s view, be disproportionate.
17. The conditions imposed by the Conditions of Practice Order were as follows:
(1) You must undertake the following two courses before seeking any Dietetic employment or placement. Certificates and written reflections evidencing the same should be provided to the first reviewing panel of:
A. satisfactory completion of Skills Platform (Documentation and Record keeping, level 2) CPD accredited online course; and,
B. engagement in HCPC standards webinar series (Standard 10 keep records of your work.
(2) Before undertaking any supervised Dietetic employment, you must successfully complete the HCPC Return to Practice requirements for those out of the profession for two to five years.
(3) You must confine your professional practice to employers who have teams of dietitians and have experienced clinical supervisors. You must not work as an independent practitioner.
(4) You must not carry out clinical dietetic practice unless supervised by a HCPC registered dietitian with a minimum of three years regulated practice.
(5) You must provide the HCPC with details of your supervisor within 28 days of commencing work under their supervision.
(6) You must develop in collaboration with your supervisor a Personal Development Plan which is targeted towards addressing the failings identified by the final hearing panel.
(7) You must allow your supervisor to provide information to the HCPC about your progress towards achieving the aims set out in your Personal Development Plan.
(8) Your supervisor must supply a report to the HCPC 14 days prior to any review hearing, in which they confirm that there are no causes for concern arising from your practice. Your supervisor should provide any reviewing panel with evidence of compliance with these conditions.
(9) You must promptly inform the HCPC if you cease to be employed by any employer or take up any other or further employment.
(10) You must promptly inform the HCPC of any disciplinary proceedings taken against you by your employer.
(11) You must inform the following parties that your registration is subject to these conditions:
A. any organisation or person employing or contracting with you to undertake professional work;
B. any agency you are registered with or apply to be registered with (at the time of application);
C. any prospective employer (at the time of your application).
18. The Order was imposed on 22 August 2023. After the time during which the Registrant could have appealed against the decision and Order imposed, it came into effect on 19 September 2023. The Order is due to expire on 19 September 2025. The decision of the present Panel is to decide what, if any, sanction is required from that date.
Submissions to the Panel
19. On behalf of the HCPC, the Presenting Officer outlined the background to the case and summarised the decision of the final hearing panel. When providing her submissions on behalf of the HCPC, Ms Khorassani stated:
“The Panel have the discretion to impose whatever Order they deem to be suitable. I have been instructed to ask that the Panel extend the Order to allow the Reg another opportunity to engage. [Redacted] However, the Reg may choose to return to work. Consequently, I have been instructed to ask the Panel to consider extending the COP. However, of course they can make whatever decision they wish. I have already mentioned the options available, you can extend the Order, impose a Suspension Order or a Strike Off. The LA has already mentioned this and will go through this when they give their advice.”
20. When asked by the Panel for the rationale for that submission, the Presenting Officer first replied that the appropriate order would be a matter for the Panel’s discretion. [Redacted] and that this was, “only the first substantive review”.
21. No submissions by or on behalf of the Registrant, beyond the communications referred to in explaining why this hearing has proceeded in her absence, have been received.
Decision
22. The Panel accepted the advice it received and followed the guidance contained in the HCPTS Practice Note entitled, “Review of Article 30 Sanction Orders”. What a panel undertaking a review of a substantive sanction order is required to do can be summarised as follows:
• The reviewing panel is obliged to accept as settled the finding of facts made by the final hearing panel and also the decision of that panel in relation to the statutory grounds determined by that Panel to be made out.
• The task of the reviewing panel is to decide whether the Registrant’s fitness to practise remains impaired, and, if it is, whether the existing order or some other order needs to be in place upon the expiry of the existing order.
• Included in the issues to be considered are those listed in paragraph 12 of the Practice Note. The reviewing panel is required to consider whether all the concerns raised in the original finding of impairment have been sufficiently addressed. In reaching its decision, it is appropriate for the reviewing panel to take the view that the Registrant carries the persuasive burden of demonstrating that matters have been satisfactorily addressed.
• If the reviewing panel is of the view that a registrant’s fitness to practise remains impaired and that a further order is required upon the expiry of the exiting order, then ordinary sanction principles apply. The decision should be made by following the guidance contained in the HCPC’s Sanctions Policy. It is necessary that any further order decided upon should satisfy the requirement that it represents a proportionate response.
The Panel confirms that in reaching its decision it has applied these principles.
23. As its powers at this review, the Panel accepted the advice it received that the finding of misconduct has the consequence that the entire sanction range up to, and including, striking off is available. However, the Panel also noted the Legal Assessor’s observation that the notice of hearing sent to the Registrant on 16 July 2025, did not include striking off as a possible outcome.
24. The Panel started its deliberations by identifying the reasons why the final hearing panel decided that the Registrant’s fitness to practise was impaired in August 2023, and whether all or any of those reasons had been satisfactorily addressed by the Registrant. The previous finding was based on poor record keeping and poor clinical reasoning in relation to very significant number of service users. It also included recommendations that were not clinically justified, with no supporting evidence base. These shortcomings were serious and repeated and had the potential to impact on the service users receiving safe and effective treatment. The Registrant’s insight into those shortcomings was very limited in August 2023 and there was a risk that she would repeat behaviour of the sort found against her. Both the personal and public components of impairment of fitness to practise were engaged in August 2023.
25. There is no suggestion made by or on behalf of the Registrant (who, as noted, carries the persuasive burden in relation to the issue) that any steps towards remediation have been taken. It follows that the Registrant’s fitness to practise is no less impaired at the present time than it was in August 2023. Indeed, the fact that it is now more than seven years since the relevant employment ended, and there is no suggestion that the Registrant has practised as a Dietitian in the meantime, it is likely that her fitness to practise is further impacted.
26. This finding has the consequence that a further sanction is required when the present Order expires. In deciding what that sanction should be, the Panel reviewed the available sanctions in an ascending order of seriousness.
27. A caution order would not be appropriate because it would provide no protection to service users from the risk of repetition. The Panel then considered the further period of conditions of practice requested by the HCPC. In view of the contents of the email from the Registrant’s Solicitor sent on 12 August 2025, the Panel considered that there was no logical basis for that submission. To impose a conditions of practice order at the present time would be inconsistent with the guidance contained in paragraph 107 of the HCPC’s own Sanctions Policy, which begins, “Conditions will only be effective in cases where the registrant is genuinely committed to resolving the concerns raised and the panel is confident they will do so.”
28. The rejection of a further period of a conditions of practice order necessarily had the consequence that the Panel arrived at consideration of a suspension order. Having carefully considered the matter, the Panel concluded that a suspension order should be made. The reasons why this is required are the following:
• Were the Registrant to return to practise as a Dietitian without undertaking, at the very least, the remedial steps contemplated by the Conditions of Practice Order, she would present an unacceptable risk to service users.
• It is clear at the present time that the Registrant will not be undertaking, at least in the foreseeable future, the remedial steps that would be necessary for it to be decided that she could be permitted to return to practise.
• In these circumstances, a suspension order is the least restrictive outcome that can be imposed.
• It would not be appropriate to make a striking off order at the present time so that the Registrant will have an opportunity to further engage with the process and persuade a future panel that her name should remain on the Register should that be her wish.
29. When the Panel decided on the appropriate length of the Suspension Order to be imposed, it considered that it should be made for a period of 6 months. The Suspension Order will come into effect on 19 September 2025 and run until 19 March 2026. Mention was made yesterday of the possibility of Registrant applying for voluntary removal from the Register. The Panel acknowledges that consideration of voluntary removal falls outside any jurisdiction it has, and, accordingly, it makes no comment about that save to note that the period of the Suspension Order will be sufficient for that issue to be considered, and if decided upon, put before a panel of the Conduct and Competence Committee for a decision as to whether it would be appropriate.
30. It is important, however, that the Registrant should have a clear understanding of the powers that a panel will have if the future Suspension Order is reviewed. That future panel will have the power to make a striking off order, and, if that review occurs, the Registrant would be well advised to consider that striking off will be an outcome decided upon without there being very cogent reasons advanced why some other, and less restrictive, outcome should be ordered. A greater degree of engagement in the process by the Registrant and further evidence of any inhibiting factors should be considered minimum steps for her to take. Beyond that guidance, because of the reasons why a Suspension Order is being imposed, the Panel does not consider that in the context of this case that further recommendations are either necessary or helpful.
Order
Order: The Registrar is directed to suspend the registration of Aparna Srivastava for a period of 6 months upon the expiry of the existing Order.
Notes
The Order imposed today will apply from 19 September 2025. This Order will be reviewed again before its expiry on 19 March 2026.
Hearing History
History of Hearings for Miss Aparna Srivastava
| Date | Panel | Hearing type | Outcomes / Status |
|---|---|---|---|
| 12/03/2026 | Conduct and Competence Committee | Review Hearing | Suspended |
| 13/08/2025 | Conduct and Competence Committee | Review Hearing | Suspended |
| 22/08/2023 | Conduct and Competence Committee | Final Hearing | Conditions of Practice |
| 10/01/2023 | Conduct and Competence Committee | Final Hearing | Adjourned part heard |
| 08/02/2022 | Conduct and Competence Committee | Final Hearing | Adjourned |