Mrs Javeria Khan

Facts Proved: 1, 2, 3, 4, and 5, in their entirety
Facts Not Proved: None
Grounds: Misconduct Found
Fitness to Practise Impaired: Yes
Sanction: Striking-Off Order

Preliminary Matters
Service

1.          The Registrant attended remotely and there were no issues of service.

Application to Restrict Hearing Time

2.          The Registrant attended from her home in Pakistan. Due to the difference in time zone, the Registrant was unable to attend after 14:00pm UK time due to family care responsibilities. There were other time restrictions due to Panel members having unavoidable other commitments on days one and two. Mr Collins, on behalf of the HCPC did not object to an alteration in the hearing times to accommodate all matters. The Panel accepted legal advice that it had an inherent power to adjust the times of the hearing in order to ensure a fair hearing and to secure the full and effective participation of the Registrant. None of the intended witnesses would be inconvenienced. In all of the circumstances, the Panel decided to rise earlier in the day to allow for the restraints on hearing time. In order to compensate, all parties agreed to sit from 08:30am UK time except on day two (which would begin at 12:00pm noon UK time) to maximise the time available.

Papers
3.          At the outset of the hearing, the Chair confirmed that the Panel had been provided with the following documentation:

• a Final Hearing bundle of 633 pages;
• a Final Case Summary of 141 pages;
• an application for the hearing to be in private by the Registrant of 1 page; and
• the Registrant’s written documents of 60 pages.

Late Documents
4.          On 30 October 2025, during her submissions on the facts, the Registrant sought to have admitted late, without objection, the statement of unused material of Applicant 3 of 7 pages. Rule 10 permitted documents to be received ‘late’. Rule 10(b) permitted the Panel to allow the documents (relying on the civil procedure Rules) but in any event, Rule 10(c) permitted the Panel a wider discretion to permit the document to be received if it was fair and was necessary to protect members of the public by doing so.
5.          The Panel recognised that the unsigned statement of Applicant 3 was not open to the scrutiny that was afforded when witnesses were available to be asked questions about it. However, there was no objection from Mr Collins and the statement was relied on for reference in an allegation that had been admitted.
6.          The Panel also recognised that the civil procedure rules (Rule 10(b)) allowed for the late receipt of evidence. In the case of The Nottinghamshire and City of Nottingham Fire Authority (Claimant) and Gladman Commercial Properties (Defendant & Part 20 Claimant) and Nottingham City Council [2011] EWHC 1918 (Ch), it was said that the most important duty of a trial Judge is to enable all parties to a trial have the fullest opportunity to present their cases provided they are presented in a way which is not unfair to the other side.
7.          The Panel considered that it was fair in all the circumstances to admit the document late for the limited purposes of submissions. It was necessary to protect the public by allowing a late document which would facilitate a full and effective hearing.

Application for the Hearing to be Heard in Private
8.          The Registrant invited the Panel to conduct the hearing in private. She submitted that the conduct of the hearing in open session was likely to result in irreparable to her relationships with her family, [redacted].
9.          Mr Collins, on behalf of the HCPC objected to the entirety of the hearing being held in private. He pointed out that the HCPTS Practice Note ‘Conducting Hearings in Private’ last updated in February 2025 explicitly said that departing from open justice was something to be justified exceptionally and that the embarrassment of publicity was not a sufficient justification for doing so.
10.       The Panel accepted the Legal Assessor’s advice and took into account Rule 10 of the Conduct and Competence Procedure Rules 2003. The Panel also had regard to the HCPTS Practice Note ‘Conducting Hearings in Private’ and it had regard to the parties’ submissions. The Panel also carefully considered the public interest grounds in the case being heard in public.
11.       Having considered the Registrant’s application, the Panel was satisfied that in the event that any matter emerges referencing the Registrant’s or any other party’s private and family life, those matters should be heard in private. It was necessary to do so in order to maintain respect for the Registrant’s right to a private life among other persons. The Panel was satisfied, however, that there was no wider justification for hearing the entire hearing in private. The application made by the Registrant was therefore refused to that extent.

Admissions by the Registrant
12.       On 27 October 2025 at the outset of the hearing, the Registrant made formal admissions to:

• Head of Allegation 1 (except for Applicants 5 and 6 whom she states she does not know); and
• Head of Allegation 2 (except in relation to Applicants 5 and 6 whom she states she does not know and Applicant 3 who was not asked for payment).

13.       On 29 October 2025, the Registrant having heard submissions by Mr Collins on behalf of the HCPC, also admitted Particular 3, 4, and 5.

Application by the Registrant to Admit Late Evidence at the Impairment Stage
14.       The hearing had originally been scheduled for five days, from 27 to 31 October 2025. On 31 October 2025, having heard submissions from both parties in respect of misconduct and impairment, the Panel retired to deliberate. There was insufficient time for the Panel to announce and hand down its decisions on misconduct and impairment and the case adjourned part heard. 
15.       At the resumed hearing, on 18 February 2026, before the Panel handed down its decisions on misconduct and impairment, the Registrant  applied to adduce further evidence relevant to the consideration of impairment. The Registrant provided information which included:

1. correspondence with the College of Physiotherapists of Manitoba (Canada) to the effect that she was suspended by the HCPC;
2. an undated letter from the HCPC to the effect that there were no restrictions on the Registrant’s practice; 
3. HCPC clarification of the Registrant’s deregistration (interim suspension); and
4. an employer’s reference. 

16.       The Registrant submitted that the evidence was relevant and wanted the information to be included for the Panel to consider before it made its decision. Ms Buckell, on behalf of the HCPC, did not object to the Registrant’s application, but invited the Panel to consider case management considerations, and the risk that the additional information may add to the allocated time available. 
17.       The Panel heard and accepted the advice of the Legal Assessor.
18.       The Panel was satisfied that the information may be relevant to its considerations on impairment, in particular the personal component. It appeared to relate to a practical example which the Registrant submitted demonstrated she had been open and honest with the Canadian Regulator regarding an administrative error by the HCPC about her professional standing. In relation to the reference from employer, this supported that she was a good practitioner.
19.       In relation to fairness, the Panel was mindful that the Registrant was unrepresented and so less knowledgeable of the legal process. Noting that Ms Buckell did not object to its admission, the Panel considered that it would be fair to admit the information.
20.       The Registrant also requested that the additional information should be kept private. Ms Buckell objected to the request, submitting that it did not fall into any of the categories identified within the HCPTS Practice Note which would justify being in private for the protection of the Registrant’s private life or in the interests of justice.
21.       The Panel had regard to the previously accepted legal advice provided by the Legal Assessor regarding hearings in private. The Panel did not consider that the additional information impacted on the Registrant’s health, family or personal circumstances, such that would justify the information remaining private.

Background
22.          The Registrant is a registered as Physiotherapist.
23.          The HCPC received a referral on 19 June 2024 from Lolita Eidukaite, Registration Manager at the HCPC, to advise that the HCPC had received a number of applications for HCPC registration, from international route applicants, which contained identical information.
34.          Ms Eidukaite took up enquiries into this matter which included writing to Applicant 1 who confirmed that they had purchased information and case studies from the Registrant after viewing the Registrant’s Facebook page, which offered ‘support’ to HCPC applicants.
25.          Applicant 1 admitted that their application was not their own work and provided screenshots of correspondence with the Registrant, including that the Registrant had asked for £250 to prepare case studies and that Applicant 1 had made two payments of £125 to the Registrant.
26.          Ms Eidukaite located five further applications for registration containing identical material. Applicant 1 and Applicant 2 admitted to paying and obtaining a drafted Further Information Form (“the Form”) from the Registrant. Four other applicants did not make any such admissions.
27.          The degree of overlap between the applications was incorporated in an annexe, Annex A (the application comparison) provided for the Panel and exhibited by Ms Eidukaite showing identical material between six applications for registration, LE 19 to LE 24.

Evidence
Applicant 1
28.          Applicant 1 affirmed and provided sworn testimony that her statement dated 21 April 2024 was true and accurate. She confirmed that the associated exhibits were hers and that the contents were accurate.
29.          Applicant 1’s evidence was that in 2017, she obtained a Doctorate in Physical Therapy from the University of Lahore in Pakistan. Between 2019 and 2022 she worked in Pakistan clinically as a Physiotherapist and as a lecturer. Her role included the assessment of patients, diagnosis, planning treatment in conjunction with Senior Physiotherapists, providing a prognosis, discharging patients, and then planning follow-up consultations. She stated that she also managed several inpatients such as Cardiorespiratory, Post-surgery and Gynaecology. Applicant 1 was employed by the University of Lahore as a Lecturer, teaching assigned subjects, setting, and marking papers, and invigilating and conducting examinations.
30.          In August 2023, Applicant 1 completed a Master of Science and Advanced Physiotherapy Practice at the University of Coventry. Applicant 1 intended to join the HCPC register as a Physiotherapist. Applicant 1 decided to research the internet for assistance in completing her registration and joined a number of groups offering help with HCPC registration on Facebook around January 2023. One group was created and administered by the Registrant on 11 April 2021 offered paid registration assistance services. The Registrant associated her profile as a registered Physiotherapist on the page. Applicant 1 exhibited screenshots of the pages with her statement.
31.       Applicant 1 explained that she grew concerned at a seeming three-month delay by the HCPC in completing her registration which she had submitted on 16 October 2022. On 26 January 2023, the HCPC wrote to Applicant 1 asking her to complete the Form in relation to Applicant 1’s past professional experience and for a reflection using the Gibbs Reflective Cycle which asks for reference to six distinct stages; description, feelings, evaluation, analysis, conclusion, and action plan.
32.       Applicant 1 explained that she became anxious regarding the completion of the Form and accordingly sought assistance from the Registrant. The Group page seemed to show 2,000 followers and had numerous positive testimonials attesting to success in joining the Register as a result of the Registrant’s help. The Registrant explained her payment terms, through her husband’s (“Person 7”) bank account, and made a number of payments, totalling £250 having negotiated a discount from the sum of £300 at first demanded. In return, the Registrant provided Applicant 1 with a completed Form containing patient details, which if not fictitious, were not details of any patient that Applicant 1 had treated or had contact with. Applicant 1 exhibited screenshots of the pages with her statement supporting these matters.
33.       The completed version of the Form provided for Applicant 1 by the Registrant, included some case studies which related to musculoskeletal, neurological, and cardiorespiratory system. This did not meet what Applicant 1 had asked for relating to the Gibbs Reflective Cycle. The Registrant had also made errors relating to Applicant 1’s professional qualifications. The Registrant then supplied a second completed version of the Form by email, with these points corrected. The second Form contained an additional error to be corrected.
34.       On 30 January 2023 Applicant 1 submitted the falsely detailed Form to the HCPC as part of her application and paid the balance of the Registrant’s charges.
35.       Between 27 February 2023 and 12 May 2023 Applicant 1 exchanged messages with the Registrant regarding her anxiety that the HCPC had not processed her application to join the Register.
36.       On 5 June 2023, the Registrations Manager at the HCPC, informed Applicant 1 that the HCPC had detected having received applications for registration from other applicants which had identical details to Applicant 1’s. Applicant 1 immediately contacted the Registrant demanding an explanation. The Registrant responded that the HCPC had only noticed a similarity in writing style, based on the multiple Forms that the Registrant had completed for others, but that the details in the Form were bespoke for Applicant 1.
37.       The Registrant and Applicant 1 then began an increasingly heated exchange of messages, resulting in Applicant 1 receiving a refund. Applicant 1 also identified another person who was in the same position, Applicant 2, and they also began corresponding. It emerged that each had received an identically detailed false Form from the Registrant, although the Registrant denied to Applicant 1 that this was the case.
38.       On 12 June 2023, the HCPC informed Applicant 1 that her application contained exactly the same information as some other applications that had been received and were word-for-word the same documents. Applicant 1 said that she felt ashamed of her actions but finally explained to the HCPC what she had paid for and provided to the HCPC with assistance in its investigations of this matter.
39.       On 16 June 2023 she explained to the HCPC in an email that she had paid the Registrant to provide her with a completed Form which she had then submitted.

Applicant 2
40.       Applicant 2 affirmed and provided sworn testimony that her statement dated 15 May 2024 was true and accurate. She confirmed that the associated exhibits were hers and that the contents were accurate. Some of the exhibits were screenshots of Facebook posts made by a friend of Applicant 2 on her behalf. Applicant 2 explained some potential exhibits in the form of WhatsApp messages were no longer available because she had lost the phone which held those messages. However, Applicant 2 was confident that she could accurately recall the content of those now-lost posts.
41.       Applicant 2 told the Panel that she had been a post graduate Master’s degree student in Glasgow in October 2022, studying Advanced Physiotherapy Practice. She had moved to Glasgow on 8 October 2022. Applicant 2 had completed a bachelor’s degree and doctorate in Physiotherapy in Pakistan and had registered as a Physiotherapist with the Pakistan Physical Therapy Association.
42.       Applicant 2 had been aware that the Registrant was a Physiotherapist, and working as a Physiotherapist but knew nothing else about her.
43.       On 27 December 2022, Applicant 2 applied to join the HCPC Register via the International Route as an overseas qualified candidate. Part of the application required Applicant 2 to complete the Form. Applicant 2 was under stress at this time due to family health matters in Pakistan which she was unable to assist with due to having relocated to the UK. She therefore sought the help of a friend, who is not a registered health professional, to help her with the Form.
44.       The Registrant’s friend made contact with the Registrant after having conducted a search online for help groups related to HCPC registration. Applicant 2’s friend contacted the Registrant and negotiated a price for assistance in completing the Form in February 2023. The Registrant agreed a price of £250 which was paid in instalments, partly through another friend of Applicant 2, who was suspicious of the service offered by the Registrant. She withheld paying the final £50 until satisfied that the completed Form would result in Applicant 2’s successful registration. Payments were made to Person 7’s bank account.
45.       The Registrant supplied Applicant 2 with detailed content for the Form which included case studies of patients that, if not fictitious, were at least not patients that Applicant 2 had any contact with. Applicant 2 submitted the Form as representative of her own work and experience as a Physiotherapist, which was inaccurate. Her intention was to secure an entry on the HCPC Register. Applicant 2 exhibited the Form with her statement.
46.       The HCPC contacted Applicant 2 after what she regarded as an unexpectedly long delay. Applicant 2 became concerned. In social media exchanges with the Registrant in March 2023, Applicant 2 sought reassurance that the Form would be acceptable.
47.       The HCPC had observed that details on Applicant 2’s Form were identical to details of case studies supplied by other applicants for registration. Applicant 2 admitted that the case studies were not her own and agreed to assist the HCPC in its investigation of the Registrant.
48.       In February and March 2023, Applicant 2 made a PDF copy of the Registrant's Facebook Group, which she exhibited with her statement. This confirmed that there were numerous candidates getting onto the HCPC Register with the help of Registrant. One such entry read “…I got registered as a Physiotherapist in just 13 days! I would like to thank Mrs Khan for her excellent services…”.
49.       The Registrant’s profile had said that she provided paid consultations for HCPC applications, although this later changed to say that the Registrant was a Physiotherapist working for the NHS. Applicant 2 saw that a lot of people had posted to say that the Registrant had helped them with their application for registration with the HCPC. Applicant 2 took screenshots of these to send to some friends in Pakistan who were also considering applying to the HCPC, to show them where they could find help with their applications.
50.       On 17 May 2023, the HCPC wrote to Applicant 2 noting that the Form that she had provided was identical to documents that had been received from other applicants. In the email, the HCPC asked for confirmation that the Form was her own work. Applicant 2 forwarded this correspondence to the Registrant that day to ask why this was the case. The Registrant’s response was to encourage Applicant 2 to evade the inquiry from the HCPC. Applicant 2 was told to provide the HCPC with "XYZ" names, meaning that Applicant 2 should give the HCPC random names from Pakistan, so that the HCPC would not know that her document was identical to anyone else's.
51.       The Registrant said that the HCPC were “…playing around with applicants but did not know anything”. The Registrant told Applicant 2 that the HCPC was providing “…stupid” outcomes for applicants after they had submitted their Form. Applicant 2 exhibited this exchange with her statement. Applicant 2 was told by the Registrant that if she provided random names, the HCPC would not be able to check them as the names would not be listed with applications. In this way, Applicant 2 would then be registered. Applicant 2 exhibited this exchange in with her statement.
52.       The Registrant told Applicant 2 in a WhatsApp exchange “…my case studies are with many colleagues that are already registered with the HCPC. I cannot believe [Applicant 2’s application] is word to word document. U need to bring them to stage where they will ask u to submit another further information”.
53.       On 17 May 2023, as instructed by the Registrant, Applicant 2 replied to the HCPC and told them that the Form was her own work.
54.       On 6 June 2023, Applicant 2 received a second email from the HCPC saying that her application was identical to some other applications. The HCPC asked for the names of the people with whom Applicant 2 had shared her application. After discussion with the Registrant, who had reassured Applicant 2 that no other person had been supplied with the details on the Form which had been provided to Applicant 2, she emailed the HCPC to confirm that her application was her own work. The Registrant then supplied Applicant 2 with a different Form containing details that were not Applicant 2’s work. Applicant 2 concluded that the Registrant had supplied her erroneously with a Form intended for another person. Applicant 2 therefore made minor amendments to the Form and submitted it as a substitute Form in her application for registration on 8 June 2023.
55.       On 10 June 2023, Applicant 2 asked the Registrant for a refund, which was done.
56.       On 12 June 2023 Applicant 2 was contacted by the HCPC, noting that Applicant 2 had not supplied the names of the people from whom she had received assistance, and that it was necessary for her to provide this information. Applicant 2 did not reply to this email.
57.       Subsequently, Applicant 2 was contacted by Applicant 1 who had a similar experience in regard to her own HCPC registration.
58.       Applicant 2 said that on 16 June 2023, Person 7 called her and tried to convince her not to give the Registrant's name to the HCPC. Applicant 2 told him that the Registrant had done something wrong. Person 7 called again but Applicant 2 did not answer.
59.       On 19 June 2023, the HCPC again emailed asking for the full name of the registered senior Physiotherapist that had assisted her with her application. At this point, Applicant 2 explained the entire matter to the HCPC.

Registration Manager
60.      Ms Lolita Eidukaite affirmed and provided sworn testimony that her statement dated 18 December 2024 was true and accurate. She confirmed that the associated exhibits were hers and that the contents were accurate.
61.       Ms Eidukaite explained to the Panel that she is a Registration Manager at the HCPC, and since 30 January 2021 has been responsible for managing international processes as well as an operational team within the Registration Department that covers the processes around registering health and care professionals onto the HCPC register. Prior to this, she was a Team Leader in the Registration Department of the HCPC.
62.       In relation to the HCPC Application Process for UK Applicants, Ms Eidukaite explained that there is a material difference between the registration process for UK applicants and for international route applicants.
63.       A UK applicant must complete a UK qualification that has been approved by the HCPC, which is usually through a university. On graduation, registration is achieved by an application Form which, is assessed by the HCPC, by a Registration Adviser who will check the form and the evidence provided. If the applicant's university have provided a list of the people who have completed the qualification, the Registration Adviser will check to see if the applicant appears on this list. Once the Registration Adviser has determined that the application is successful, the applicant will be asked to provide a registration fee and they will then be registered with the HCPC.
64.       International route applicants have a different process because the variation in job roles and standards in other countries. The HCPC must be satisfied that international route applicants will meet the HCPC's standards before they are allowed to practise in the UK.
65.       International applicants apply to the HCPC through an online portal on the HCPC's website. The applicants are asked to complete the following steps during the application process:
Section 1 — Your details
Section 2 — Your qualification
Section 3 — Professional experience
Section 4 — Professional registration and membership
Section 5 — English language proficiency
Section 6 — Declarations
66.       The applicants are then asked to submit their application and pay a scrutiny fee of £639.98. Once this has been received, the application is reviewed by a Registration Adviser. The Adviser will check that all of the information provided is certified, for example, the university certificates must have been stamped correctly. The Adviser must also send verification requests to the relevant universities to verify that the work experience listed on the applications is true and accurate.
67.       The Registration Adviser will then send the application to two Assessors who work as a pair to review the application. The Assessors will check if the applicant meets all of the HCPC's Standards of Proficiency for the relevant profession. The general expectation of individuals to be honest and integral is outlined within the HCPC's Standards of Conduct, Performance and Ethics ("the Standards"); the standards in place at the time of these concerns is exhibited as Exhibit LE1. In the event that some of the Standards have not been met, the usual process is that the Assessors will recommend that the applicant is asked to submit further information or take a competency test. The competency test involves being interviewed via Microsoft Teams and the further information gives the applicant a chance to submit more written information to the Assessors. The further information request is found at Exhibit LE2.
68.       Ms Eidukaite explained that if further information is requested, the Assessors will indicate which Standards of Proficiency are missing and give suggestions as to what the applicant should submit in order to meet those standards. The applicant is given 28 days to submit the further information, but they can ask for an extension.
69.       Ms Eidukaite reviewed the Registrant’s application which included her signed declaration. Ms Eidukaite observed that the declaration signed by the Registrant does not specifically mention the need to ensure that the Form is their own work, and not plagiarised, however, the general expectation of individuals is to be honest. This is integral and is outlined within the Standards.
70.       On receipt of the further information form, the Assessors will review the information provided and assess if the applicant meets the outstanding proficiencies. If this is the case, the Assessors will recommend that the applicant is registered with the HCPC. If there are still unmet standards, the Assessors may recommend a competency test or reject the applicant. As such, each applicant receives a record of assessment, which is filled out by the assessors.
71.       Ms Eidukaite exhibited the records of assessments for all the six Applicants in this matter.
72.       Even in instances where applicants cover the same standards as UK applicants, they would be expected to submit distinct information. Case studies are inherently unique to the individual international route applicant, given that they involve the applicant's explanations of patient specific details, including symptoms, treatment plans, follow ups and other matters. Ms Eidukaite said that in this investigation, contact was made with the six applicants when the HCPC team noticed the similarities in their Further Information. Some of the applicants admitted to purchasing case studies from the Registrant. Ms Eidukaite exhibited this to the Panel.
73.       Ms Eidukaite said that as a Registration Manager, she would not normally review the applications but did in this investigation because of a complaint received by an applicant.
74.       On 13 March 2023, two Assessors noticed that two applicants had submitted the same information within their Form. The Assessor informed a Registration Adviser, who then forwarded the email to Ms Eidukaite. The email included the applicants' application numbers and explained that there was evidence of collusion in the further information that had been provided. Material from two initial applicants was identified as identical, Applicant 2 and Applicant 4. After this, the Assessors began to notice further Forms with the same information contained within them.
75.       On 1 May 2023, one of the Assessors sent an email to the HCPC to identify three applications that had submitted the same information in their Form, Applicant 5, and Applicant 6. On 1 June 2023, the HCPC received another email identifying that Applicant 3 had also submitted identical material to the others in this case. In total, six applicants were identified by one pair of assessors.
76.       At the time of these discoveries, the HCPC did not have any plagiarism software in place, nor did they have a plagiarism policy in place. However, the applicants are required to make a final declaration at Section 6 of the application process when submitting their application which confirms the applicant's good standing and character as well as their qualifications. This declaration was in place when the applicants submitted their further information forms. The Assessors had to manually compare the applications to check whether they contained the same information. Ms Eidukaite exhibited the applications for each of these applicants which all included the declaration that they understand that “fraudulently procuring an entry into the HCPC register is a criminal offence....”
77.       On 17 May 2023 Ms Eidukaite contacted Applicants 2 and 4 raising concerns. She subsequently wrote to Applicants 1, 3, 5 and 6. They responded asserting that the work was their own and had been supported by following YouTube videos. Ms Eidukaite was dissatisfied and again wrote to the applicants. In response, Applicants 1 and 2 admitted having purchased the materials from the Registrant. Applicant 3 admitted only having discussed the application with the Registrant as a senior colleague. Applicant 6 and Applicant 4 said that they had made use of the Registrant’s Facebook group as peer support. Applicant 5 was adamant that their Form was their own work, although supported by accessing online materials. Applicant 6 did not accept that her submission was identical to others, asserting that they used NHS England and Facebook materials as peer support only.

The Registrant
78.       The Registrant affirmed and provided evidence on her own behalf. She relied on her written submissions provided in the Final Hearing Bundle which stated:
“Self-Reflection.
I started practising as a Physiotherapist in Pakistan in 2011. I got registered with Pakistan Physical Therapy Association (PPTA). PPTA is the body representing the interests and protecting the rights of Pakistani physiotherapists and their patients. Providing a unified platform for all the Physiotherapist's needs. I worked as a Physiotherapist for 12 years and during that duration, I ensured compliance with relevant laws, regulations, and guidelines governing healthcare practice in Pakistan which included adhering to standards for documentation and record-keeping, billing practices, scope of practice limitations, and professional liability insurance requirements. I always prioritised patient safety and quality of care by following best practices, protocols, and guidelines endorsed by professional associations, and regulatory bodies. My good standing certificate is the evidence of my compliance with regulatory requirements and my reputation as a trustworthy and competent Physiotherapist in Pakistan. I am happy to provide references or testimonials (if requested) from colleagues, supervisors, or hospital who can attest to my professional competence, integrity, and good standing as a Physiotherapist in Pakistan & United Kingdom.
When I moved to UK, I worked for Surrey Physio group. My biggest mistake there was I never contacted HCPC to ask if making Facebook page like this is allowed or not. When it came into HCPC knowledge, I instantly turned down my Facebook page before my first hearing. When HCPC scheduled me for hearing, I accepted my mistake then at the first hearing which was happened because of total lack of knowledge. It was an unintentional mistake. I understand that being a Registrant it is my responsibility to know the standards and code of conduct of the profession and in my case, I did not know the standards in depth. Therefore, although it is the Registrant responsibility to know the standards and ethical values of profession, my mistake was that I have not learnt about that. I have learnt that being a healthcare professional, it's crucial to be familiar with the ethical principles and guidelines that govern your practice. I did ethics courses to stay committed to investing time and effort into learning about the standards and ethical values of my profession. I know I did a mistake therefore instead of denying it, I accepted it and I know that I am accountable for my actions and decisions. I should have maintained clear boundaries between my personal and professional activities.
[…redacted] I was unintentionally engaged in an activity that was perceived as exploiting my professional status. I have learnt that I should have contacted HCPC to know about the details of having Facebook page like this. When my hearing process started, I remained honest and cooperated with HCPC team at every step. I am sincerely apologising to HCPC for the harm I caused and took steps to improve myself by to turning down my page and by doing ethical courses and cooperating fully with any regulatory processes or investigations.
I was extremely disheartened, but I understood that this discipline process is the price that I have to pay for my unprofessional conduct. I am vigilant to continue to maintain my physiotherapy registration in good standing in Pakistan and adhere to all relevant professional standards and regulations to show my ongoing commitment to ethical practice. […redacted] I have done Ethics courses along with reviewing several resources on HCPC website related to ethics and professionalism. (Ethics Courses attached).
Right now, dealing with a […redacted]      is a very stressful and challenging situation for me and my family, but I tried to be resilient, and persistent in pursuing resolution. Due to this disciplinary action, I am dealing with emotional and psychological effects, including stress, guilt, shame, and loss of self-esteem. I understand that rebuilding trust with regulatory bodies is a gradual process that requires consistent demonstration of ethical behavior and accountability over time. Therefore, I can reassure that I am committed to maintain compliance with regulations and ethical standards in the future.
In conclusion, I am going to highlight the points about what have I learnt from my experience.
Although it is extremely important to maintain professional boundaries, I understand that I did an unintentional and honest mistake due to lack of awareness and the incident was not a result of deliberate disregard for regulations or ethical standards, but it was inappropriate. I sincerely apologise for my act. I believe that acceptance of misconduct is often the first step towards rebuilding trust and it is essential for repairing relationships and restoring confidence in professionalism.
I take responsibility for my ethical misconduct as it can damage trust in the healthcare system and have legal and professional ramifications. I have learnt and paid the consequences of my behavior by the interim suspension placed on me for almost one year period until now. I have done ethical courses and learnt code of conducts to prevent similar incidents from occurring in the future.
I understand that it will take time and effort to rebuild trust with regulatory bodies. I can promise and assure HCPC that I will demonstrate a sincere commitment to ethical behavior through my actions and will consistently uphold the values of integrity, accountability, and respect in all my interactions, both online, and offline.
I am open to receive any feedback from the regulatory body and others about my conduct and performance when I will resume working as a Physiotherapist. Constructive feedback can provide valuable insights into blind spots or areas for improvement that I may not have recognised on my own.
I can assure that I will engage in ongoing self-reflection to deepen my understanding of the factors that contributed to the ethical misconduct. I can reaffirm my commitment to uphold professional standards and ethical guidelines in my practice. I will continuously familiarise myself with relevant codes of conduct, regulations, and best practices, and integrate them into my daily decision-making and behavior.
I can assure that I will lead my career as a positive role model for colleagues, students, and other healthcare professionals in demonstrating integrity, accountability, and responsibility in my interactions and decision-making.
 In last, I assure HCPC that I will demonstrate sincerity, accountability, and a commitment in profession and I seek understanding and leniency from HCPC for unintentional misconduct. I am also ready to do any course recommended by HCPC. I am extremely sorry for my mistake and seek leniency from HCPC […redacted] lost jobs and cannot do work [redacted].”

Decision on Facts
79.          The Panel paid close regard to the closing submissions by Mr Collins on behalf of the HCPC and by the Registrant on her own behalf.
80.          In closing submissions, Mr Collins invited the Panel to find all of the Particular proved in their entirety.
81.          Mr Collins reminded the Panel that the Registrant had largely accepted all of the facts. However, in regard to the outstanding matters, the Panel could apply the principles of cross-admissibility set out by the High Court in PSA v Garrard [2025] EWHC 318 (Admin). If the Panel was satisfied that at least one of the persons identified in Schedule A had been supplied improperly with materials by the Registrant, then that was cross-admissible in support of proof of other cases in regard to Applicants 5 and 6 as an example.
82.          Mr Collins submitted that there was evidence that the Registrant had sought to recruit the assistance of the witnesses to cover up her wrongdoing. That was evidence of knowingly having acted wrongly and dishonestly in supplying the materials for reward.
83.          Mr Collins submitted that the evidence of WhatsApp message exchanges supported that the Registrant had provided services for reward, including declining to supply materials until a suitable price had been agreed and part-payment advanced. This was evidence pointing to a financial motivation.
84.          The Registrant reminded the Panel that she accepted all of the Particular except in relation to Applicants 5 and 6 whom she does not know. The Registrant invited the Panel to find that Head of Allegation 1 was not proved to the extent that it related to Applicants 5 and 6 in Schedule A. The Registrant expressed sorrow and remorse for her actions and asked that she be treated fairly and sympathetically.
85.          The Panel accepted the Legal Assessor’s advice. It recognised that the HCPC had the burden of proving disputed facts to the civil law standard of balance of probabilities. The Registrant had no burden of proof. The Panel considered that in relation to cross-admissibility of evidence, the Registrant had not relied on or made out a rebuttal case relating to coincidence or contamination of material that would explain the identical elements of the cases studies relied on in the applications for registration by Applicants 5 and 6. She adhered only to a general denial of any contact with them. Accordingly, the Panel applied the principle of cross-admissibility of evidence in relation to propensity only.
86.          In that regard, the Panel understood that it must first be satisfied that at least one case under Particulars 1 and 2 was proved. If so, the close similarity of near-identical material in the Forms relating to those individuals could serve to establish that the only real explanation for that was the supply of the materials for reward by the Registrant based on her propensity to do so for reward.
87.          The Panel began by considering the documentary evidence available. This included a large body of entirely consistent social media exchanges between Applicants 1 and 2 and the Registrant which taken together, established that the Registrant was operating a social media platform business. The exchanges were incomplete. Applicant 2 in particular explained that some messages had been irrecoverable because she had lost her phone. The Registrant said that this explanation was inadequate. Certain messages which were favourable to the Registrant had not been produced. Those messages sat between messages that had been produced. Accordingly, if a missing device explained their absence, it was improbable that related messages immediately before and afterwards would be available.
88.       The criticism made by the Registrant had some force, when considering the reliability of Applicant 2. However, more importantly for the Panel, the messages that were produced were not subject to any challenge of having been altered or edited. The Panel therefore had a consistent and logically coherent chain of message exchanges which assisted in understanding the nature of the parties commercial relationship and the course of dealings between them.
89.       The Panel also had copies of the Forms provided as part of a registration application for all six applicants. The details in the Forms were striking in their closely similar detail. The Registrant accepted authorship of the details on the Forms. She provided them to Applicants 1 to 4 on a non-gratuitous basis. The Registrant had accepted that she had been aware of other persons offering online services to assist applicants for HCPC registration for remuneration.
90.       The Registrant also opened a social media page designed to attract customers in the same way and published favourable testimonials from satisfied customers who attested to the speed and efficiency of their registration applications being granted thanks to the Registrant’s efforts. There was evidence in the uncontested papers that the Registrant had directed customers to her private social media page enterprise which required paid access by interested parties. Person 7 had made a bank account available to take payments and he assisted in dealing with customers in the administration of payments. The Registrant offered to provide detailed assistance in making successful HCPC registration applications, but only for a price. In the front page of the business headed “HCPC Registration Services for Applicants” dated 11 April 2021, the Registrant’s profile explained that “I provide paid consultations for HCPC professionals”.
91.       Applicant 1 sought assistance with her registration application and enquired “and what are your service charges as well?” to which the Registrant responded “…I do write further information requests but I charge £300 for that and £500 for full application. As u need further information, will charge £300.” When asked “Mam, will you please give me a discount? This would be a great help”, the Registrant responded “I am soo sorry. First time application is easier to do that further information. Why? Because that is the last chance fairly given to the applicant”.
92.       Applicant 1 asked about follow-up with the HCPC. The Registrant responded, “Follow-up means that communication os (sic) done by the applicants but I write the emails and answers to any query that HCPC ask for”. In response to Applicant 1 the Registrant had also written “…u need to pay have of the amount when u want me to start writing for you and half of it when I will let you know that ur document is ready. Then I will send you the document as soon as u pay me the remaining amount….” This exchange was associated with evidence provided to the Panel that Applicant 1 had paid Person 7 £125 on 26 January 2023.
93.       There was also other evidence that the Registrant insisted on being paid £400 for her services, although there was also substantial evidence of price negotiations for less than that sum with applicants. Importantly, the Registrant would not supply services without payment.
94.       The Panel was also provided with documentary evidence that payments had been made and accepted via a bank account operated by Person 7 to facilitate these transactions.
95.       The Panel was satisfied that although incomplete, the contemporary documentary evidence was substantial and persuasive. Whatever criticism that could be made of the reliability of Applicants 1 and 2, the case against the Registrant in Heads of Allegation 1 and 2 was fully supported by the independent contemporary documentary evidence.
96.       The Registrant had admitted, except for Applicants 5 and 6, the Particular 1 and 2. The Registrant said that she had no contact with Applicants 5 and 6. However, the Panel was satisfied that there was no evidence that the Registrant provided services other than for reward through her social media enterprise. She had admitted supplying further information in Forms to Applicants 1 to 4. The details of the Forms for these Applicants were strikingly similar in many respects and identical in many passages. The details of the Forms in relation to Applicants 5 and 6 were in precisely the same category and the only explanation for that was the Registrant’s common authorship.
97.       The Panel was satisfied that the cross-admissibility of evidence provided for by the Garrard decision established that the Registrant had the propensity to commit this form of misconduct, including providing material on payments being made by customers. The Panel was satisfied that Applicants 5 and 6 could only have obtained their Forms in the same way and on the same commercial basis that Applicants 1 to 4 had done. The Panel was not assisted by the unsigned statement of Applicant 3 in relation to payments for services.
98.       In all of the circumstances and taking the Registrant’s formal admissions into account, the Panel was satisfied that Particulars 1 and 2 were each proved in their entirety.
99.       The Panel took into account that the Registrant had now admitted Particulars 3 and 4, that her actions in Particulars 1 and 2 respectively were dishonest. The Panel also took into account the test for dishonesty set down by the Supreme Court in Ivey v Genting Casinos [2017] UKSC 67. The Panel had been provided with a copy of the Registrant’s own declaration on making her application to join the HCPC Register which made it clear that the contents of the application and supporting information must solely be the work of the Registrant.
100.       The Panel was satisfied that the Registrant must therefore have known that providing other applicant’s with material in the Forms that was not related to their own work and experience for the purposes of securing registration was something that any decent ordinary person would regard as being dishonest.
101.       Further, the Panel took into account that the Registrant had taken steps to secure the agreement of Applicants 1 and 2 to keep her identity as the author of the Forms concealed from the HCPC. She provided refunds to Applicants 1 and 2. She had encouraged them to try to circumvent the HCPC’s investigation by adding further false details to the submissions in a way that was designed to obfuscate the Forms’ common authorship, consistent with her knowledge of her culpability.
102.       The Panel was satisfied that in providing such illicit material was a dishonest thing for the Registrant to do.
103.       The Panel considered that it followed that taking money for such an improper enterprise was also a dishonest thing to do. The Registrant had admitted this in the course of the hearing. However, the Panel considered that it was a logically inescapable conclusion. The design of the scheme had been to permit applicants to circumvent the protections in place to protect the integrity of the HCPC Register. Accepting money for doing so was inherently dishonest as the Registrant must have realised at the material time.
104.       The Registrant also accepted in the course of the hearing that her actions had been financially motivated. The Panel considered that there was little difficulty in the whole circumstances in finding this Particular proved. The Panel had already set out the social media exchanges which exemplified in Applicant 1’s posts, the commercial nature of the bargains reached with all of the applicants. The Registrant had made it clear that without payment, the services would not have been provided.

Decision on Grounds
105.       Having found all of the facts in Particulars 1 – 5 proved, the Panel went onto consider Particular 6, the grounds of misconduct.
106.       Mr Collins made oral submissions to the Panel, inviting it to find that the grounds of misconduct were made out in this case.
107.       Mr Collins referred the Panel to a number of cases including Roylance v GMC [2000] 1 AC 311 and Nandi v GMC [2004] EWHC 2317 (Admin). He referred the Panel to the guidance provided in the HCPTS Practice Note ‘Fitness to Practise Impairment’ dated August 2025.
108.       Mr Collins submitted that the facts found proved by the Panel were extremely serious. The Registrant’s conduct was a direct threat to the integrity of the Register, was done knowingly for profit and with absolute disregard for the safety of patients and service users who may be placed at risk by potentially unsuitable applicants being admitted to the Register fraudulently. He further submitted that the Registrant’s actions breached Standard 9 of the Standards and amounted to misconduct. A finding of dishonesty was always a solemnly serious matter, highly corrosive of the trust placed by the public in the integrity and probity of a registered Physiotherapist.
109.       The Registrant, on her own behalf, accepted that her actions were serious and amounted to misconduct.
110.       The Panel accepted the advice of the Legal Assessor. In considering the statutory grounds, the Panel took into account the submissions of Mr Collins and the Registrant, all of the relevant evidence and its prior Findings on Facts.
111.       The Panel was aware that in respect of misconduct there was no standard or burden of proof. Any finding of misconduct was a matter for the Panel’s own professional judgement. It held in mind that breaches of the Standards were matters that were highly relevant.
112.       The Panel concluded that the Registrant’s conduct in Particulars 1 – 5 was very serious. The Panel considered that public trust and confidence in the integrity of the Register was a matter of fundamental importance. The public must be able to trust that any registered Physiotherapist is a safe, effective and trustworthy practitioner. Without that, members of the public might be hesitant to secure appropriate treatment for themselves and their loved ones. Taking steps which had the effect of assisting others to circumvent the rigorous way in which registration is gained and, in effect, promoting the making of false representations to the Registrar for personal gain was a fraud on the Regulator and on the public.
113.       The Panel also considered that service user safety had been placed at risk by the Registrant’s commercial activities. The Registrant’s actions had been a calculated and methodically executed course of conduct, which had continued for so long and on such a scale that the Registrant was unable, in her social media messages, to identify how many persons she had been engaged by.
114.       The Panel had regard to the additional information which had been submitted by the Registrant on 18 February 2026. The Panel did not consider that it changed its decision on misconduct, where the seriousness of the conduct itself was being considered.
115.       The Panel determined that the following Standard was engaged and breached:
Standard 9. Be Honest and trustworthy.
Personal and professional behaviour
9.1    You must make sure that your conduct justifies the public’s trust and confidence in you and your profession.
116.       The Panel determined that both individually and cumulatively, the Registrant’s actions admitted and found proved in Particulars 1, 2, 3, 4 and 5 fell seriously short of the Standards to be expected of a registered physiotherapist and amounted to misconduct.

Decision on Impairment
117.       Having found that the statutory grounds of misconduct had been made out, the Panel moved on to consider the question of impairment.
118.       Mr Collins had again provided the Panel with oral submissions. He again referred the Panel to the HCPTS Practice Note ‘Fitness to Practise Impairment’ and submitted that the Registrant’s current fitness to practise was impaired on both the personal and the public elements of impairment. The Registrant had, he said, expressed remorse. However, she had not provided the Panel with sufficient evidence to support the conclusion that her past failings were now remedied and were very unlikely ever to be repeated.
119.       Mr Collins said that the Registrant had provided some limited evidence of insight, but far short of what was necessary to satisfy the public that the Registrant had remedied her actions. In these circumstances, the public would readily conclude that the Registrant having so profoundly undermined the integrity of the Register and having acted dishonestly repeatedly, was at risk of doing so again.
120.       Mr Collins said that a distinction could be drawn between a single spontaneous act of dishonesty arising in unexpected circumstances, and the Registrant’s planned and mature enterprise. The Registrant had not immediately ceased her activities when the Registrar opened an investigation and had not been open and candid. Instead, she had kept silent and had recruited Applicants 1 and 2 among others, to try to obscure her central part in this damaging disregard for the integrity of the Register.
121.       Mr Collins also submitted that the public’s trust and confidence in the HCPC as a regulator would be seriously diminished were a finding of impairment not made.
122.       Mr Collins invited the Panel to find the Registrant’s fitness to practise was currently impaired.
123.       The Registrant submitted that while her fitness to practise had been impaired at the time that that these matters occurred, that was not the case today.
124.       The Registrant said that she had reflected carefully and deeply on her past misconduct. She was ashamed of her actions and that was set out in detail in her reflections referred to already.
125.       The Registrant said that she had completed a demanding online course related to professional ethics. She had learned some important lessons and would never engage in such activities in the future.
126.       The Registrant explained that she had been a Physiotherapist for more than 12 years. There had never been any complaint regrading her professional competence or treatment of patients. The Registrant said that she could supply references from her past employer in the UK if asked.
127.       The Registrant told the Panel that she had returned to Pakistan with her family. She would like to resume practice in her home state but was unable to focus her attention and commit to this while this matter was unresolved.
128.       The Panel accepted the advice of the Legal Assessor. In reaching its decision, the Panel had regard to the cases of GMC v Meadow [2006] EWCA Civ 1319, CHRE v NMC & Grant [2011] EWHC 927 and Cohen v GMC [2008] EWHC 581 (Admin).
129.       The Panel recognised that impairment of current fitness to practise can be found even where the misconduct does not arise directly from the Registrant’s professional practice as set out in the Meadow case. The Panel had regard to consider both the personal and public components as set out in the HCPTS Practice Note ‘Fitness to Practise Impairment’. The Panel understood that its decision must be grounded in the protection of the public as set out in the case of PSA v NMC [2017] CSIH 29.
130.       In reaching its decision on current impairment, the Panel took into account the submissions of Mr Collins on behalf of the HCPC and the Registrant on her own behalf. The Panel also took into account all other relevant evidence before it and its prior decisions on facts and grounds. The Panel was aware that the question of impairment was a matter for it exercising its own professional judgement.
131.       The Panel first considered the personal component. The Panel came to the view that, with difficulty and with clear insight and targeted remediation, all of the Registrant’s misconduct was remediable.
132.       The conduct was attitudinal in nature and driven by placing her financial needs before the interests of patients and the public in placing the integrity of the Register at risk, for money. The Registrant had supplied fabricated patient details for applicants to use directly in their applications, without any enquiry as to their ability to actually conduct the treatments referenced in the Forms. There was no evidence, even as the hearing developed and the matter was canvassed at length, of insight into the potential for harm to patients and the damage to the integrity of the Register. The Panel noted that after the HCPC investigation had begun, and applicants were being asked to be candid about the origin of the Forms supplied, the Registrant encouraged them to supply other falsified details in order to frustrate the enquiry and prevent her conduct coming to light.
133.       It was a matter of concern that the Registrant repeatedly made the point that she had refunded the applicants. Accordingly, she insisted, she had full insight and had acted to remedy the concerns. She stated that the Panel could be reassured by this that there would be no repeat of this or any other misconduct.
134.       There was, however, no offer of meaningful insight by the Registrant into her understanding of why the integrity of the Register is so fundamental to patient safety, to maintaining the essential trust and confidence of the public and in regard to maintaining professional standards.
135.       The Panel was entitled to expect that any registrant in the Registrant’s position would have at least considered the declarations that the applicants were each expected to have signed truthfully and her part in fabricating and supplying case studies in defiance of the declarations. She had encouraged the applicants to disregard the obligations expected of them as though the HCPC’s investigation was unnecessary and intrusive, and frustrating the enquiry was a trivial matter, professionally.
136.       The Panel concluded that the Registrant had in reality taken no real meaningful steps, based on genuine insight that was not merely self-referential, to remedy her shortcomings. The Registrant had been dishonest, which is a profoundly serious matter. The Registrant had not addressed that matter directly and had instead avoided the issue, as though her apology and expressions of remorse was enough.
137.       It was difficult for the Panel not to see a parallel with the Registrant’s approach to the applicants’ concerns. She had told them to give the HCPC any names, or say seniors helped, as the HCPC would not then be able to draw a connection between the Forms and their common authorship. She had encouraged them to respond falsely to the HCPC.
138.       The Panel had regard to the additional information submitted by the Registrant on 18 February 2026. The Panel acknowledged that it appeared to be an instance whereby the Registrant had been candid with another Regulator regarding her professional status with the HCPC. However, the Panel also bore in mind that professional standards require a registrant to be open and honest both with their current and prospective Regulator. As such, the Registrant, as a minimum, was obliged to draw to the prospective Regulator’s attention, the apparent mistake of her current Regulator regarding her professional status.
139.       The Panel also acknowledged the reference from a previous employer, which confirmed that she was a capable practitioner. However, the Panel did not consider that this reference addressed the honesty and integrity issues which concerned the Panel.
140.       The Panel did not consider that the additional information supplemented the Registrant’s insight to demonstrate that it was developed to a level where she understood the public protection and public interest considerations of her misconduct. In the Panel’s view, the additional information did not address whether the Registrant understood the risk of potentially unsafe practitioners being admitted to the Register as a consequence of her actions. Further, it did not demonstrate that she appreciated the fundamental importance of the integrity of the Register and how her action may damage the public’s trust and confidence in it and the Physiotherapy profession.
141.       In these circumstances, the Panel concluded that the Registrant had not remedied her past failings. Further, the Panel could not be satisfied that there would be no repeat of the Registrant’s past failings in this or any other context. The Panel did not consider that the Registrant had taken  any meaningful practical steps to begin the process of remediation, and was left with the impression that she did not understand the need to remediate beyond having repaid the money to the Applicants and removing the Facebook account.
142.       The Panel considered that the Registrant had demonstrated that she was a capable and highly intelligent person. She could, had she thought it relevant to her case, have independently anticipated and addressed the Panel’s concerns even before the hearing began. She had not done so in any meaningful way even as the hearing progressed. The Panel concluded that the core issue in this matter, the Registrant’s underlying attitude to her failings, was not seen by her as a real failing at all. She appeared to be more concerned to achieve some sense of comparative justice, repeating that it was unfair that the applicants in this case might still be considered for registration despite their culpability in the enterprise being equal to her own.
143.       For all of these reasons, the Panel concluded that the Registrant’s fitness to practise was currently impaired in respect of the personal component.
144.       In respect of the public component, the Panel considered each of the three elements separately, albeit within the context of an overall professional exercise of judgement.
145.       The need to protect service users by ensuring the integrity of the Register is not compromised was, in this case, an important matter for the Registrant to show insight, remorse and practical steps in remediation. However, the Panel considered that the Registrant has not demonstrated that she truly understands the function of the regulatory process and the role of the Register to protect the public and maintain public confidence. It appeared to the Panel that she viewed the Register as an administrative obstacle to be overcome and if possible to her own financial advantage.
146.       The Registrant had not shown that she has the necessary insight so as to be unlikely to repeat her past actions. She presents, in the Panel’s judgement, a serious and ongoing future risk to service users.
147.       In regard to the other two elements of the public component, maintaining professional standards and public confidence in the profession concerned, the Registrant had not reassured the Panel that she has understood the risks of harm created by her and the steps necessary to begin remediating her past failings.
148.       The HCPC has set out the Standards it expects of registrants, in particular, in relation to her proved dishonesty. The Panel considered that the Registrant had not upheld Standard 9. Members of the public and other registrants had a right to expect that all registrants will uphold all of the Standards at all times. The public expect, rightly, that registrants will place the public’s interests before the registrants’ own personal interests including their financial interests.
149.       The public must have full confidence in the registrants who treat them and who might treat them after being admitted to the Register. The public is entitled to expect registrants to act with decency, honesty, and integrity. The public should also be able to rely on the Registration process to be robust, fair, and transparent. The Panel came to the view that given the nature of the allegation and the facts found proved, public confidence in the Physiotherapy profession and how it is regulated would be seriously undermined if there were to be no finding of impairment.
150. The Panel therefore determined that the Registrant was currently impaired in relation to the public component.
151. The Panel therefore determined that the Registrant’s current fitness to practise was impaired both in respect of the personal and public components.

Decision on Sanction
152.       Having concluded that the Registrant’s fitness to practise is currently impaired, the Panel went on to consider what would be the appropriate, proportionate and sufficient sanction or other outcome in this case.
153.       Ms Buckell, on behalf of the HCPC took the Panel through the HCPTS Sanctions Policy (“the Policy”) and identified that the primary function of a sanction is to protect the public, with considerations in this regard including: any risks the Registrant might pose to those who use or need their services; the deterrent effect on other registrants; public confidence in the profession concerned and public confidence in the regulatory process. She submitted that the question of sanction was a matter for the Panel, but pointed out some of the factors present in the current case which may be relevant for a more serious sanction.
154.       The Registrant apologised again for her actions and stated that she knew what she had done was wrong. She said she understood that she had broken public trust and confidence and that she must account for what she did on a personal and a professional level. She said she was open to undertake any training she needed to improve herself as a professional and was happy to do anything to improve herself to regain the trust of the regulator and the public. She said she had thought she was on the right path with the information she had provided about her honesty and said she would like to accept any recommendations from the Panel, because she wanted to remediate and show insight and remorse.
155.       The Panel accepted the advice of the Legal Assessor. It had regard to the Policy and adopted a stepped approach, considering 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 public interest, which includes upholding standards within the profession, together with maintaining public confidence in the profession and its regulatory process.
156.       The Panel identified the mitigating and aggravating factors, and evaluated them in respect of each sanction under consideration, in accordance with the case of O v NMC [2015] EWHC 2949 (Admin).
157.       The Panel considered the following to be mitigating factors in this case:

1. no previous issues or regulatory concerns;
2. the Registrant has engaged in the process;
3. the Registrant has undertaken some relevant courses; and
4. the Registrant has apologised for her action.

158.       The Panel considered the following to be the significant aggravating factors in this case:

1. the Registrant has limited insight, in particular regarding her understanding of the seriousness of the dishonesty and its implications on public protection and public confidence;
2. there was repetition of the dishonesty involving at least six Applicants, which occurred over a significant period of time;
3. the Registrant sought to persuade other individuals to keep her details private so as to avoid discovery of her dishonesty;
4. the Registrant’s actions were for financial gain;
5. the Registrant played an active role in the dishonesty in planning and coordinating it;
6. the impact of the Registrant’s dishonesty was that it enabled potentially unsafe Applicants to be admitted to the Register; and
7. there was an element of abuse of position, in that it was her role as a qualified Physiotherapist registered with the HCPC which facilitated the dishonesty.

159.       The Panel did not consider the options of taking no further action or mediation to be appropriate or proportionate in the circumstances of this case. Neither would address the ongoing risks, including the risk of repetition which the Panel had identified at the impairment stage. In any event, the Panel considered that the case is too serious and neither option would meet the significant public interest considerations, including the importance of maintaining the public’s confidence in the integrity of the Register and the regulatory process.
160.       The Panel did not consider that a caution order would meet the seriousness of this case. The Panel bore in mind the concerns it had regarding the risk of repetition due to the Registrant’s level of insight, in particular her apparent lack of understanding of the consequential risk to the public resulting from her actions in enabling potentially unsafe practitioners to be admitted to the Register. The Panel did not consider that a caution order would address the ongoing public protection and public interest concerns.
161.       The Panel next considered a conditions of practice order. The Panel had regard to paragraph 108 of the Policy, which states that conditions are less likely to be appropriate in more serious cases, for example those involving dishonesty. The Panel also noted the observations in paragraphs 106 and 107 of the Policy, whereby insight was regarded as a significant factor for conditions to be suitable so a panel could be confident that a registrant would be able to resolve their failings. The Panel considered that the dishonesty in this case was directly linked to the practice of Physiotherapy although it was committed outside of the workplace. The Panel also bore in mind its ongoing concerns regarding the Registrant’s level of insight. In such circumstances, the Panel did not consider that it was possible to formulate workable and verifiable conditions which would appropriately manage the risk. In any event, the Panel did not consider that a conditions of practice order was sufficient to maintain public confidence in the profession or the HCPC as its Regulator, as the case was too serious.
162.       The Panel next considered a suspension order. It acknowledged that such an order would protect the public for the period which it was in place, but recognised that this was not the only consideration. The Panel had regard to paragraph 121 of the Policy which states:
“A suspension order is likely to be appropriate, where there are serious concerns, which cannot be reasonably addressed by a conditions of practice order, but which do not require the registrant to be struck off the register. These types of cases will typically exhibit the following factors: 

• The concerns represent a serious breach of the Standards of conduct, performance, and ethics [the Standards]; 
• The registrant has insight;
• The issues are unlikely to be repeated; and
• There is evidence to suggest the registrant is likely to be able to resolve or remedy their failings.”

163.       In considering the factors set out in paragraph 121 of the Policy, the Panel was satisfied that the Registrant’s misconduct represented serious and repeated breaches of the Standards over a period of time. However, in relation to the other factors indicating when a suspension order may be appropriate, the Panel noted its own concerns about the Registrant’s insight, in particular her apparent lack of understanding of the seriousness of her actions and the consequential risk of harm to the public and public confidence. The Panel also noted its findings at the impairment stage that the Registrant’s lack of understanding of this risk of harm meant there was an ongoing risk of repetition. 
164.       The Panel acknowledged that there was some remorse and also an apology from the Registrant, particularly at this late stage of proceedings, but the Panel considered that this focussed on herself as opposed to demonstrating an appreciation of the impact her actions had on the Regulator and the integrity of the Register. The Panel noted that the Registrant had undertaken some relevant training. However, it did not appear to the Panel that such training had contributed to the Registrant’s learning and development of insight such that she appreciated the seriousness of her actions and consequential risk of harm to the public and the public interest. The Panel did not consider that there was sufficient evidence to suggest that the Registrant would be likely to resolve or remedy her misconduct, given her apparent fundamental lack of understanding as to why it was so serious and how it may impact on public protection and damage public confidence in the profession and the regulatory process.
165.       Given that the Policy did not appear to indicate that a suspension order was appropriate or sufficient, the Panel went on to consider a striking-off order. The Panel had regard to paragraph 130 of the Policy, which identifies that a striking-off order is a sanction of last resort for serious, persistent, deliberate or reckless actions involving dishonesty. As previously identified, the Panel considered that the dishonesty was serious, given the consequential risk of unsafe applicants being admitted to the Register and the risk of damage to public confidence in the integrity of the Register. The Panel considered that the Registrant’s dishonesty had been persistent, as it had been repeated over a period of time and involved at least the six Applicants listed at schedule A of Particular 1. The Panel also considered that it had been deliberate, in that it had been for financial gain. The Panel had regard to paragraph 131 which states:
“A striking off order is likely to be appropriate where the nature and gravity of the concerns are such that any lesser sanction would be insufficient to protect the public, public confidence in the profession, and public confidence in the regulatory process…”
166.       The Panel considered that in the particular circumstances of this case, a striking-off order is the only sanction which is sufficient to protect the public and maintain public confidence in the profession and the regulatory process.
167.       The Panel was mindful of the principle of proportionality when considering the appropriate sanction. It acknowledged that such an order will preclude the Registrant from working as a Physiotherapist within the UK and may cause her significant hardship. However, the panel was of the view that only a striking-off order was appropriate in this case and no lesser sanction would serve the purpose of both protecting the public and meeting the wider public interest.

Order: The Registrar is directed to strike the name of Javeria Khan from the Register on the date this Order comes into effect.

Interim Order
Application
1.          Ms Buckell, on behalf of the HCPC, applied for an interim order of suspension for 18 months to cover the appeal period before the Striking-Off Order comes into effect. She submitted that an interim order was necessary to protect the public and was otherwise in the public interest to cover the duration of the appeal period, given the seriousness nature of the findings.
2.          The Registrant made no submissions.

Decision
3.          Panel heard and accepted the advice of the Legal Assessor and had regard to the Practice Note on ‘Interim Orders’.
4.          The Panel considered whether an interim order was necessary to protect the public and concluded one was necessary. The Panel has found misconduct and current impaired fitness to practise on both the personal and public components, in respect of serious dishonesty which had a consequential impact on public protection and public confidence in the profession. The Panel found that the Registrant’s limited insight meant that there is a risk of repetition. The Panel, therefore, concluded that an interim order was necessary to protect the public.
5.          The Panel also considered the wider public interest. The Panel concluded that, having found that the Registrant’s fitness to practise is currently impaired, and that the only appropriate sanction is one of a striking-off order, the public would be concerned if the Registrant were permitted to practise during the appeal period. It, therefore, concluded that an interim order was required to maintain public confidence in the profession and to uphold proper standards of conduct and behaviour.
6.          Accordingly, the Panel concluded that an interim order is necessary to protect the public and is otherwise in the public interest.
7.          The Panel considered an interim conditions of practice order, but in light of the Strike-Off Order, the Panel was of the view the case was too serious to be dealt with by way of conditions for the same reasons as set out in the substantive hearing. 
8.          In all the circumstances the Panel determined to make an interim suspension order for a period of 18 months. In deciding to impose this length, it took account of the fact that if the Registrant were to appeal, that process may take a considerable period of time.

The Panel therefore makes an Interim Suspension Order under Article 31(2) of the Health Professions Order 2001, the same being necessary to protect members of the public and being otherwise in the public interest.

This order will expire: (if no appeal is made against the Panel’s decision and Order) upon the expiry of the period during which such an appeal could be made; (if an appeal is made against the Panel’s decision and Order) the final determination of that appeal, subject to a maximum period of 18 months.

Right of Appeal
You may appeal to the High Court in England and Wales against the Panel’s decision and the order it has made against you.

Under Article 29(10) of the Health Professions Order 2001, any appeal must be made within 28 days of the date when this notice is served on you. The Panel’s order will not take effect until the appeal period has expired or, if you appeal, until that appeal is disposed of or withdrawn.

History of Hearings for Mrs Javeria Khan