Aiwanehi Sandra Aigbokhaevbo

Background

1. The Registrant is registered with the HCPC as a Dietitian.

2. On 13 March 2024, the Registrant attended an interview via Microsoft Teams for a Band 5 Oncology Dietitian role at Royal Surrey County Hospital (the Hospital). The interview was conducted remotely via Microsoft Teams.  

3. The interview panel was based at the Hospital and comprised TK, Head of Service for Dietetics and Speech and Language Therapy, LA, Macmillan Oncology Dietitian and Oncology Team Lead and ZB, Surgical Oncology Dietitian.  The Registrant was based in Nigeria.

4. All of the interviewers came to the view that the Registrant was using artificial intelligence (AI) to answer the clinical questions they asked in interview because:

• She was repeating the questions put to her and stalling before answering.

• Her speech when answering questions was more eloquent than in general conversation.

• Her speech when answering questions sounded like she was reading from something.

• Her eye movements when answering questions had the appearance of someone reading from another screen.

• Her answers had a ‘textbook’ quality to them.

5. Subsequently, the Registrant completed a case study. 

6. Again, the interviewers came to the view that the Registrant had used AI. On this occasion because:

• The answer was too detailed, particularly by reference to comparator interviewees and apparent stalling in interview.

• The answer included knowledge which a band 5 dietitian of her experience would not be expected to have (both in terms of medical side effects and UK specific guidelines).

• The answer used full terminology where acronyms are standard in dietetic practice. This was even more unusual given that the case study needed to be completed within 45 minutes.

7. After the interview, ZB input the case study and one of the questions into ChatGPT (an AI program) and noted significant similarities between the answers provided by ChatGPT and the Registrant’s answer, both in terms of form and substance.

The hearing 

8. The Panel was provided with a hearing bundle which included the witness statements of the three members of the interviewing panel referred to above. They exhibited the Registrant’s application for employment with the Trust, their interview notes, the Registrant’s case study and the AI comparators provided by ZB.

9. The Panel heard evidence from the Registrant and was provided with a number of character references in her support. The Registrant had also provided a written response to the Allegation dated 15 March 2025, which was included in the hearing bundle

The evidence 

10. TK adopted her witness statement dated 24 April 2025. In summary she stated that:

• She had not encountered the Registrant before the interview but noted that she had applied previously for multiple jobs advertised at the Hospital. 

• The job for which the Registrant applied was a Band 5 Oncology Dietitian entry level role at the Hospital. 

• The interviewing panel were together in a meeting room at the Hospital. The interview was conducted via Microsoft Teams and took place on 13 March 2024. The Registrant attended remotely from Nigeria with her camera and audio switched on. The Registrant was required to wait in the Microsoft Teams waiting room prior to being admitted to the main interview room.

• The panel members each made their notes on separate copies of the same proforma, which contained the questions, along with some expected answers to certain questions which were completed during the course of the interview. 

• The interview started with two questions of a general nature concerning the Registrant’s interest and experience in dietetics; it was followed by questions of a clinical nature.

• The Registrant’s response to the first two questions showed great enthusiasm and spontaneity.

• When asked questions of a clinical nature, the Registrant’s response altered noticeably: she became very hesitant, she asked the panel to repeat the questions a number of times and she herself then repeated the questions back very slowly and deliberately. After much hesitation and repetition of the questions, the Registrant would then articulate with great fluency a model answer, rather than answering from her own knowledge and experience. The answers she provided were as if from a text book, indicating specialist knowledge and experience of an advanced level, referring to medical terminology which were beyond the expectations of the job role.

• TK reached the conclusion that the Registrant was reading her answers to the clinical questions: her eye movements went from side to side, and she appeared to be reading her answers from another screen; her manner of speech and delivery indicated that she was reading, rather than answering spontaneously; there were no natural breaks or pauses for thought

• TK stated that it appeared that the Registrant was repeating the questions put to her, in order to input them in an AI platform, then reading the results from the screen as her answer.

• The interview had to be abandoned at around question 7 as a result of the failed internet connection at the Registrant’s end. When asked about the effect of the internet connectivity problems on the interview, she stated that they had been able to get through most of the interview, before the Registrant started to drop out.

• With regard to her interview notes, TK confirmed that they were written contemporaneously in the course of the interview and each panel member’s notes were written independently and without any input from the other panel members

• Following the interview, the Registrant was asked to complete a case study within 45 minutes. TK concluded that the study provided by the Registrant had been written using AI: it was too detailed and perfect to be the Registrant’s own work. For example, TK would not have expected a dietitian to know about medical side effects, all of which were listed in the case study. It also made reference to NICE guidelines which the Registrant was unlikely to know about, not having worked in UK dietetics.

• TK agreed, when questioned by Ms Wright, that they had noted particular problems with candidates from Nigeria using AI in applying for jobs. She denied being biased against the Registrant and stated that she herself had been an overseas applicant and had been empathetic to the Registrant’s situation.

11. ZB adopted her witness statement dated 15 April 2025 which can be summarised as follows:

• She confirmed that the Registrant’s response to the first two questions in interview was enthusiastic and spontaneous.

• In response to the clinical questions, the Registrant’s body language and articulation noticeably changed; she became hesitant, asked the questions to be repeated multiple times and herself repeated parts of the questions back multiple times. After a long period of silence, the Registrant would come out with a very fluent and detailed answer.

• ZB noticed the Registrant’s eye movements appeared as if reading from a screen. ZB noted in her interview notes to question 3 ‘? Reading from screen’.

• In response to question 6, the Registrant repeated the question to herself a number of times and appeared to be stalling. She suddenly gave a very fluent answer which included a lot of technical jargon. Her eye movements were consistent with someone reading from a screen.

• ZB confirmed that the internet connection failed completely at around question 7 and the interview was then terminated.

• With regard to the case study, ZB was surprised that the Registrant had been able to provide such a fluent, extensive and detailed answer within 45 minutes.

• ZB was suspicious that the Registrant had used AI both when answering questions in the interview and for the purpose of her case study. Following the interview, she put the case study through an AI platform which produced a case study very similar to that provided by the Registrant. She also put question 6 into AI, which led ZB to the same conclusion

• ZB exhibited the results of her second input onto Chat GPT, which was produced as part of her evidence for the hearing   and highlighted it to indicate similarities with the Registrant’s case study.

• ZB confirmed that her interview notes were her own, that they had been written contemporaneously with the interview and independently of the other panel members.

12. LA adopted her witness statement dated 18 April 2025 as her evidence.

• She confirmed that the Registrant’s response to the first two questions in interview showed a genuine interest in the role she was applying for and a passionate interest in advancing her career in dietetics.

• She stated that a noticeable change occurred with question 3, when the questions focused on the Registrant’s clinical knowledge. The Registrant became visibly hesitant and appeared to struggle.  She asked the panel to repeat the question three times and her tone and facial expression suggested confusion. The Registrant herself then repeated the question several times. Once she started answering the question, her response shifted dramatically: she provided a highly comprehensive, structured and articulate answer that included a wide range of side effects with their dietary implications. It was the sort of answer that might be expected of a candidate with several years of specialist oncology experience, not someone applying for an entry level role.

• When giving her answers, LA formed the clear impression that the Registrant was reading the answers from a screen: her eyes were shifting from side to side, and her delivery was in a structured and flowing manner.

• The Registrant’s answers to clinical questions continued in the same manner during the rest of the interview with hesitation and numerous repetitions of the questions being followed by comprehensive and highly structured answers.

• LA recorded her impressions in her interview notes, which she stated were written contemporaneously, independently and without reference to her colleagues on the panel. She had queried in her notes after question 3 whether the Registrant was reading her answers. She said that by question 6, she was confident that the Registrant was reading her answers from a screen.

• She stated that the Registrant’s case study was more comprehensive than any that she had seen before.

• Her conclusion was that the Registrant had used AI when answering the interview questions and in her case study.

• LA confirmed that the internet connection had broken down at or around question 7. She denied that it had interfered with the interview until that stage.

• It was suggested to LA in cross-examination that she may have been biased against the Registrant, having been made aware that there had been problems with other applicants from Nigeria using AI. LA vehemently denied any bias against the Registrant. She said that the Trust prided themselves on their fairness and diversity. 

13. The Registrant’s evidence-in-chief can be summarised as follows: 

• She had undertaken a four-year course at one of the best universities in Nigeria, during which she had undertaken clinical placements, which included some experience in oncology.

• Before the interview she has sought help from other registrants who were working in the NHS, consulted textbooks and looked at webinars and material available online.

• This was her 17th job interview; she had previously applied for around 200 jobs.

• She was on her own during the interview and had no materials apart from a pen and paper; the only application open on her screen was the Microsoft Teams interview.

• She asked the interviewing panel whether she could ask them to repeat questions and they confirmed that she could. 

•She said that she repeated questions back to ensure that she had understood the question correctly and did this as a matter of “reflex”.

• She denied any hesitancy in answering questions but said that she needed to digest the question before answering.

• She said that she did look away from the screen to check on her router, located next to her laptop because her signal kept breaking up and her screen kept “buffering”.

• She denied reading anything from her screen.

• She was unable to answer question 4 because her screen froze and the panel could not really hear her. When she reconnected, she sensed that they were hostile and heard TK say “is she reading from something”. They appeared uninterested in anything else she had to say.

• On re-joining the hearing, she showed the panel a 360 degree view of her room, so that they could see that there was no-one else present, but they did not comment.

• She denied using AI at any time during the interview. She agreed that, if she had used AI, it would be cheating and would be a “great offence”

14. Under cross-examination, the Registrant stated that;

• Her last employment before the interview was in July 2023 but she had undertaken dietetic work on a part-time basis for a colleague which kept her abreast of dietetic practice. She had not thought to mention this in her application to the Trust as it was voluntary and flexible working hours. She had reported to have taken other training courses. 

• She asserted that she had asked the interviewing panel to repeat the first two questions in addition to all the other questions.

• She stated that she had asked for the questions to be repeated because of connectivity problems, but also because she always asked for questions to be repeated as a matter of course.

• She denied any hesitancy in answering questions. Any perception that her manner of speech changed after the first two questions was probably attributable to the screen buffering.

• She asserted that the panel was unable to continue with questions, because of connectivity problems, and she denied being asked question 5 and 6.

• She stated that the panel members had not being scribbling notes during the interview but had been ticking off answers.

Submissions on behalf of the HCPC

15. Mr Cassells submitted that:

• The interviewing panel comprised three professional people, with extensive clinical and interviewing experience, who had no preconceptions about the Registrant and no axe to grind.

• The Registrant’s response to questions 1 and 2 had made a very positive impression. 

• It was clear to all three panel members that the Registrant’s manner completely changed when answering the clinical questions from question 3 onwards and that she was unable to answer the questions without external assistance. That impression derived from her hesitation, frequent repetition of the questions, long pauses, followed by model textbook answers which she appeared to be reading from a screen.

• The impressions of each of the witnesses was formed independently of the others, as confirmed by their respective interview notes.

• In contrast to the witnesses for the HCPC, the Registrant’s evidence was inconsistent and unreliable. In particular, she referred in evidence to having undertaken relevant training and clinical practice which was not mentioned in her job application form; her experience and training was inconsistent with and incompatible with the apparent specialist knowledge and expertise provided in her answers.

• She improvised her evidence by making up incidents which had not occurred such as saying that she heard the panel discussing whether she was reading her answers.

• Her evidence that she was not asked questions 5 and 6 was contrary to the clear evidence of the notes of each panel member and it was apparent that the Registrant was attempting to disown the evidence contained in their notes.

• If the Panel found Particular 1 proved, it must follow that Particular 2, alleging that her conduct in relation to Particular 1 was dishonest, as on the Registrant’s own admissions using AI during an interview would be cheating therefore Particular 2 must also be proved.

Submissions on behalf of the Registrant 

16. Ms Wright submitted that:

• There was no direct evidence that the Registrant was using AI and the HCPC relied on the suspicions only of the witnesses which was insufficient.

• The evidence was consistent with an innocent explanation such as that she had relied on her own knowledge and experience and used her reading of NHS Guidelines to answer questions. 

• The impression of the Registrant’s eyes moving across the screen was consistent with her checking on her router which was blinking and dropping out. 

• There were inconsistencies in the evidence of the witnesses, such as their disagreement over the extent to which the internet connectivity problems had interfered with the interview.

• The notes of the interviewing panel were so similar as to suggest that they had relied on each other’s impressions.

• There may have been unconscious bias on the part of the panel in relation to other candidates from Nigeria apparently relying on AI.

Decision on the facts

17. The Panel took account of the submissions of Mr Cassells on behalf of the HCPC and Ms Wright on behalf of the Registrant.

18. The Panel accepted the advice of the Legal Assessor.

19. The Panel noted that the standard of proof required is on the balance of probabilities. In other words, the Panel must be satisfied that any act alleged is more likely than not to have occurred before it can find it proved. The burden of proof is on the HCPC in respect of the factual particulars.

20. The Panel found the evidence of all three witnesses on behalf of the HCPC to be credible and cogent. Any inconsistencies were immaterial to the overall effect of their evidence and were likely to be due to the passage of time.

21. The Panel was satisfied that the interview notes of each witness were made contemporaneously with the interview, that they were not added to in any material respect at the end of the interview and that the notes of each were made independently of the others without there having been any collusion between them.

22. The Panel, however, did not consider the evidence of the similarity between the Registrant’s case study and her answers to question 6 to what was produced by ZB by using an AI platform to be sufficiently clear or contemporaneous to reach any conclusion as to its provenance. In any event, the Panel was not satisfied that the Registrant’s case study was covered by the wording of Particular 1 which related to the use of AI when “answering questions during a job interview”.

23. By contrast with the HCPC witnesses, the Panel found the Registrant’s evidence to be inconsistent and unreliable in the following respects:

• The Registrant claimed that she always repeated questions as a matter of course. The Panel noted that there was no evidence of this during the course of her giving oral evidence. The Panel also accepted the evidence of LA that the Registrant only started asking questions to be repeated, and repeated them herself, when the interviewing panel asked her questions relating to clinical practice.

• The Registrant stated in her evidence that she had relevant work experience relating to chemotherapy and had undergone relevant training, none of which was mentioned in her job application form or in any responses to the allegations prior to the hearing.

• The Registrant’s explanation that the perception that she was reading from a screen was in fact attributable to the fact that she was observing her router, located beside her laptop, was not credible.

• Her assertion that she was not asked questions 5 and 6 because the internet connection had already broken down was inconsistent and incompatible with the fact that each of HCPC witnesses had independently made notes of her response to questions 5 and 6. 

• The Registrant’s suggestion that the witnesses were not making notes but were simply ticking boxes was incompatible with the evidence of their notes, which the Panel believed to have been made contemporaneously with the interview.

• Her evidence was that on reconnecting with the hearing after question 5 she heard the witnesses discussing whether she was reading her answers and this was raised for the first time during her oral evidence to the Panel. 

• Her evidence that she had moved her screen to show the interviewing panel a 360-degree view of her room seemed an unlikely response to her evidence that she heard the Panel discuss whether she was reading her answers. 

24. Having accepted the evidence of the HCPC’s witnesses, and rejected the evidence of the Registrant where it differed from theirs, the Panel was satisfied that the Registrant used AI when answering questions during the job interview as alleged in Particular 1.

25. The Registrant herself admitted that the use of AI to answer questions in a job interview would be cheating. The Panel found that by the standards of ordinary decent people would regard such conduct to be dishonest. The Panel therefore found Particular 2 also proved.

Decision on misconduct

26. The Panel went on to consider whether the facts found proved amounted to misconduct, as alleged in Particular 3 of the Allegation.

27. The Panel carefully considered the submissions on behalf of the HCPC and the Registrant respectively. On behalf of the Registrant, Ms Wright acknowledged that the proven facts constituted misconduct. 

28. The Panel accepted the advice of the Legal Assessor.

29. The Panel was mindful that this was a matter for the Panel’s professional judgement, there being no standard or burden of proof.

30. The Panel took into account that misconduct was defined in Roylance v General Medical Council (no 2) [2001] 1 AC 311 as:

“a word of general effect, involving some act or omission which falls short of what would be proper in the circumstances. The standard of propriety may often be found by reference to the rules and standards ordinarily required to be followed by a (medical) practitioner in the particular circumstances”; and
the reference in Nandi v General Medical Council [2004] EWHC 2317 to misconduct as being:

“… conduct which would be regarded as deplorable by fellow practitioners”. 

31. The Panel considered that the Registrant‘s dishonest conduct was in breach of the following HCPC Standards of Conduct, Performance and Ethics (2016):

Standard 9.1:“You must make sure that your conduct justifies the public’s trust and confidence in you and your profession”. 

Standard 9.2: “You must be honest about your experience, qualifications and skills”.

The Panel was in no doubt that the Registrant’s conduct fell seriously short of the standards to be expected of her in the circumstances and thereby constituted misconduct.

Decision on impairment

32. The Panel noted the positive character references provided by professional colleagues on behalf of the Registrant.

33. The Panel gave careful consideration to the submissions on behalf of the HCPC and the Registrant respectively. 

34. The Panel took into account the HCPTS Practice Note on “Fitness to Practice Impairment” and accepted the advice of the Legal Assessor.

35. In determining whether the Registrant’s fitness to practise is impaired, the Panel took into account both the personal and public components of impairment. The personal component relates to the Registrant’s own practice as a Dietitian, including any evidence of insight and remorse and efforts towards remediation. The public component includes the need to protect service users, declare and uphold proper standards of behaviour on the part of registrants and maintain public confidence in the profession and the Regulator.

36. With regard to the personal component, the Registrant denied the Allegation and has expressed no remorse or apology. Her dishonest use of AI was compounded by her subsequent lies and by seeking to cast doubt on the professional integrity and veracity of the HCPC witnesses. Whilst she acknowledged in her evidence that using AI to assist her in her job interview would be cheating and “a great offence”, she has shown no insight as how cheating in a job interview would:

• undermine the integrity of the recruitment process;

•have a potentially negative impact on the Trust in having to address deficits in the knowledge and expertise of the person recruited;

• potentially jeopardise patient care in being treated by a Dietitian who did have the knowledge and skills she claimed to have.

37. Given the attitudinal nature of the Registrant’s misconduct, and the absence of any evidence of remorse, insight or remediation, the Panel considered that there was a significant risk of repetition. The Panel found the Registrant to be untrustworthy in her willingness to tell lies in the course of her evidence and impugn the professional integrity of the HCPC’s witnesses.

38. The Panel therefore concluded that the Registrant’s fitness to practise is impaired at a personal level.

39. With regard to the public component of impairment, the Panel accepted the submissions on behalf of the HCPC that;

• Honesty and integrity are fundamental requirements of healthcare professionals.

• By seeking to obtain employment as an Oncology Dietitian through cheating and dishonestly representing her knowledge and skills, the Registrant potentially put patients and service users at risk of significant harm, in that she did not have the knowledge and skills she claimed to have.

• Public confidence in the profession relies on the integrity of the recruitment process, which the Registrant would have undermined had her cheating in the interview process been successful. 

• The maintenance of proper professional standards requires an unequivocal statement that dishonesty when seeking employment is extremely serious.

40. The Panel considered that public confidence in the profession and the Regulator would be undermined if there were no finding of impairment. 

41. The Panel therefore found the Registrant’s fitness to practise to be impaired in respect of both personal and public components.

Decision on sanction

42. The Panel carefully considered the submissions on behalf of the HCPC and the Registrant respectively.

43. The Panel took into account the HCPC’s Sanctions Guidance (2026) and accepted the advice of the Legal Assessor. The Panel was mindful that the purpose of a sanction is not to punish the Registrant but to protect the public and the wider public interest in upholding proper standards and maintaining the reputation of the profession. The Panel applied the principle of proportionality, balancing the interests of the Registrant with those of the public, and considered the available sanctions in ascending order.

44. With regard to mitigating factors, the Panel took into account the positive character references on behalf of the Registrant and, in particular, the reference from her team leader at the Royal United Hospitals Bath, where she has been employed since April 2025 and has been in the acute dietetic team since September 2025. The reference states that the Registrant has been trustworthy and reliable and has shown perseverance in adapting to UK practice.

45. The Panel found the following aggravating factors:

• The Registrant compounded her dishonesty in the recruitment process by casting doubt on the veracity of the HCPC witnesses, seeking to impugn their professional integrity and suggesting that they had been motivated by unconscious bias and prejudice. 

• The Registrant’s misconduct in misrepresenting her knowledge and skills for the purpose of securing employment had the potential to cause significant harm to patients and service users.

• The Registrant has provided no evidence of remorse, reflection, insight or remediation.

• Given the attitudinal nature of the Registrant’s misconduct, there is a risk of repetition.

46. A Caution Order would not be appropriate, given the serious nature of the Registrant’s dishonesty, her lack of insight and the risk of repetition.

47. A Conditions of Practice Order would not be relevant or appropriate, given the nature of the misconduct and that it does not relate to the Registrant’s clinical skills.

48. The Panel carefully considered whether to impose a Suspension Order. The Panel was not satisfied that the Registrant had insight, or that the concerns about her honesty were unlikely to be repeated. Additionally, there was evidence that the Registrant was likely to remedy her failings in being honest and trustworthy. The Panel concluded that the Registrant’s dishonest misconduct by cheating in the recruitment process, compounded by her lies when giving evidence, was fundamentally incompatible with her continued registration.

49. The Sanctions Policy states that a striking off order is a sanction of last resort for serious persistent and deliberate acts, including dishonesty and “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. In particular where the registrant:

• Lacks insight

• Continues to repeat the misconduct 

• Is unwilling to resolve matters”.

50. Whilst the Panel took full account of the financial and other hardship to the Registrant, the need to protect the public and the wider public interest must take priority over the Registrant’s interests. The Panel concluded that the appropriate sanction is a Striking Off Order. 

ORDER: That the Registrar is directed to strike the name of Miss Aiwanehi Sandra Aigbokhaevbo from the Register on the date this order comes into effect.

Please note the Registrant has appealed the Order imposed by the panel.

The Interim Suspension Order rwill remian in place until the appeal has been determined.

Interim Order

1. Mr Cassells on behalf of the HCPC made an application for an Interim Suspension Order for a period of 18 months to cover the appeal period or until any appeal lodged has been determined. 

2. Ms Wright on behalf of the Registrant did not oppose that application.

3. The Panel accepted the advice of the Legal Assessor.

4. Given the Panel’s findings that the Registrant’s actions are fundamentally at variance with remaining on the Register and a Striking Off Order has been imposed, it would be inconsistent with that need for public protection and the wider public interest not to impose some form of interim order. The Panel, for the same reasons it identified above, came to the conclusion that it is impracticable and inappropriate to formulate interim conditions of practice in this instance.

5. The Panel therefore makes an Interim Suspension Order under Article 31(2) of the Health Professions Order 2001, the same being necessary for public protection and otherwise in the public interest, having regard to the Panel’s findings of fact and determination as to impairment and sanction.

6. 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. This Interim Suspension is for a period of 18 months.

History of Hearings for Aiwanehi Sandra Aigbokhaevbo