IN THE FAMILY HEALTH SERVICES APPEAL AUTHORITY
CASE NUMBER: 11447
Mr T Jones Chairman
Dr RK Rathi Professional
Member
Mr TP Bennett Member
BETWEEN
DR RP SINHA
(GMC No: 2409467)
Appellant
AND
NORTH MANCHESTER PRIMARY CARE
TRUST
Respondent
DECISION WITH
REASONS
1. The Appeal
Dr
RP Sinha (“the Appellant”) appeals the decision of the North Manchester Primary
Care Trust (“the PCT”) of 26th August 2004 to refuse to include the
Appellant on its medical performers list in relation to areas of, firstly,
suitability (Regulation 6(1)(a)); and secondly, with regard to clinical
references (Regulation 6(1)(b)) of The National Health Service (Performers
Lists) Regulations 2004. Regulation 6(4) sets out criteria which the PCT were
bound to take into consideration prior to making a decision to refuse to
include a practitioner. Subsequent to
lodging the Notice of Appeal clinical references were provided, such that the
PCT did not oppose the Appellant's appeal in that regard, leaving only the
issue of suitability for us to redetermine.
2. Background
The
Appellant who was born in 1947, qualified in 1971, and practiced initially in
India until 1978. He began to practice
in the United Kingdom; working initially in hospitals but moving to general
practice in 1991. In 1997 as noted in
the CV produced, he joined the St Georges Medical Practice in Moston,
Manchester. This was a three partner
inner city practice. One of the principals left the practice in October 2001,
leaving the Appellant and a colleague to cope with a list of approximately
6,500 patients. The Appellant’s
remaining partner took sick leave in July 2002. The Appellant was left to cope
in this practice, with the assistance of a part time locum. Management and
financial responsibilities for the practice were left for the Appellant to cope
with, together with his clinical work.
During this time the Appellant was also experiencing personal
difficulties, in relation to a contact dispute as between the Appellant and his
ex-wife, concerning contact with the Appellant's daughter.
3. On 19th November 2002 an incident occurred at the
practice. The Appellant was later convicted in the Magistrates Courts of
allegations of common assault upon two members of the practice staff. We understand it was alleged that the
Appellant took one member of staff by the upper arms or shoulders, shaking her,
and pushed aside another member of staff, who came to assist her. At Manchester Magistrates Court on 4th
December 2003 the allegations of common assault being found proved the
Appellant was sentenced to penalties of £500.00 fine in respect of each of the
two charges; a Compensation Order of £150 was made on each count; he was
ordered to pay the cost of the prosecution set at £750.00.
4. On the 27th May 2004 the General Medical Council
(“the GMC”) concluded that this matter should not be referred to the
Professional Conduct Committee. The Preliminary Proceedings Committee concluded
matters by giving the Appellant a warning.
5. The PCT were aware of the allegations of assault from an
early stage. The PCT submitted that it
followed due process in bringing the matter to a formal hearing. There was a delay following a submission by
Dr Sinha for inclusion on the Performance List, this was largely it is said
down to a delay in obtaining a Criminal Records Bureau Report (“the CRB
Report”) in respect of the Appellant.
Dr Sinha was invited to comment upon the same, it included reference to
other matters in relation to a different allegation of assault, which was
dismissed; and, of an allegation made in relation to Dr Sinha by his ex-wife in
the context of the contact issue. At
the hearing Mr Harrop, Director of Operations for the PCT, conceded that whilst
the PCT was aware of these matters, the focus of the PCT decision was based on
the convictions for common assault; indeed, in evidence before us Mr Harrop was
noted as stating “they were in our knowledge but do not provide the weight of
our decision… they are not relevant”.
Mr Harrop also, in the context of latest witness statement in his
evidence, stated that Dr Sinha perhaps had not been aware of the focus of the
PCT enquiry, when making their decision on 26th August 2004,
particularly as regards input as to a determination made by the PCT panel as to
the relevance and seriousness of the convictions and sentence for the
assaults. Mr Harrop in his statement
and evidence put forward a view of their seriousness, basing this on his
understanding of Court procedure and practice, gained sitting as a Lay
Magistrate in an adjacent petty sessional area.
6. The hearing of the appeal
The
appeal was heard at Harrogate on 17th December 2004 by way of a
directions hearing and then set down for a full hearing on 26th
January 2005. At that hearing the
Appellant was represented by Mr Horne of Counsel. The PCT was represented by Miss Richler-Potts. Oral evidence was received from Mr Harrop,
Director of Operations at the North Manchester PCT, as well as from the
Appellant and Dr Fink, Honorary Secretary of the Manchester Local Medical Committee.
7. At the outset contained, within the skeleton arguments on
behalf of both parties to the appeal, it was understood that the jurisdiction
which the FHSAA panel operated in respect of this appeal was one by way of a
re-determination of the issues. The
burden of proving Dr Sinha is unsuitable for inclusion in its performance list
rested upon the PCT, against a standard of proof which could perhaps be
referred to as the “high civil standard”.
This being a flexible standard of proof to be applied with greater or
lesser strictness according to the seriousness of what has to be proved and the
implications of those proving those matters. The more serious the allegation
the more cogent is the evidence required to overcome the unlikelihood of what
is alleged and thus prove it. In relation to serious allegations, there may be
no difference in practical terms between the civil standard of proof and the
criminal.
8. As is stated above, evidence was received as is set out in
the Record of Proceedings, and this together with the information comprised in
the bundle of papers, has been taken fully into account by us. At the conclusion of the evidence we were
addressed in closing by the advocates for the parties to the appeal.
9. The Evidence
The
only witness called by the PCT was Mr Harrop, Director of Operations of North
Manchester PCT since 1st September 2003. He adopted his most recent statement of 18th January
2005, as being an encapsulation of earlier statements he had submitted in
connection with his matter, and was then cross-examined. In the course of
cross-examination Mr Harrop felt that the PCT had assessed the information
before it fairly. He conceded that whilst the Appellant had been written to
preceding the hearing this did not include reference in relation to the
specifics of the assault conviction and weight to be attached to the level of
sentence. Mr Harrop also had to concede
in some measure, the issue raised as regards the level of stress the Appellant
was suffering at the time of this incident was not fully discussed at the PCT
panel. Mr Harrop himself was relatively recent in post, and did not know the
Appellant, but acknowledged that the medical member of the panel would have
known of this issue. Mr Harrop considered that the level of fine, and the
overall sentence, suggested the sentence was such that the Court must have
taken the matter seriously; such that it was to be of significance and
influenced markedly the PCT panel reaching its decision.
10. Dr Sinha gave evidence and adopted as his evidence-in-chief
his two statements within the bundle and curriculum vitae annexed thereto. He
was cross-examined as to the number of patients on his list, and his efforts to
secure locum cover, prior to the incident in November 2002. He acknowledged that he was subject to
stress, but had otherwise enjoyed good patient relations within his practice.
In the past two years he said had plenty of opportunity to reflect upon the
cause of the stress which he said led to the incident, and of ways of avoiding
the same. He particularly stated that
if he felt stressed in the future, he would seek out help, without reservation.
11. Dr Fink gave evidence as to the input of the Local Medical
Committee. He gave evidence as regards the effects and pressure of a practice
list of over six thousand patients in such an area of practice.
12. At the end of the hearing we were addressed by the advocates
in turn for the PCT and Appellant.
13. Ms Richler-Potts pointed to the convictions for common assault
on former staff members, as being the basis upon which it is thought that the
Appellant is unsuitable for inclusion on the list. She submitted that the PCT decision made was balanced and fair,
and that Mr Harrop was in a position to give input at that meeting as regards
the substantial nature of the penalty imposed.
She was concerned that Dr Sinha had not demonstrated, in her submission,
remorse or expressed adequately how he would cope with stress, or identify it,
in the future. She concluded by pointing out that the PCT was not bound by the
GMC’s decision, any more than this panel should be at the conclusion of this
hearing.
14. Mr Horne, on behalf of the Appellant, reiterated the basis
upon which the advocates were approaching issues, as to the burden and standard
of proof, and that the hearing was a re-determination of the matters afresh.
15. He was at particular pains to point to the Magistrates’
Association sentencing guidelines and also as to how the PCT would be guided by
the Regulations; particularly in regards to areas of disqualification under
Regulation 6(2), and other matters which should be taken particularly into
account as highlighted within paragraph 6(4).
He prayed in aid that the position as regards those other matters
referred to in the CRB Report, were not made out in the course of hearings
determining the same, and pointed to the evidence of Mr Harrop at the hearing
that they were not relevant and urged us to take a similar view. Mr Horne also submitted, whilst it did not
bind this panel, he referred us to the decision of the GMC at pages 110 and 109
within the bundle. He also stressed
that the Appellant was otherwise a clinician with many years of experience,
without prior complaint from any patient.
16. When dealing with the key issue of risk of recurrence, he
recited that he we have the benefit of having seen and heard Dr Sinha; a man of
quiet disposition, a person who now with the passage of time has the insight to
deal with issues of stress. He reminded us, as been put in his evidence today the
Appellant would not have the slightest reservation to seek out help. His
workload would never again be likely to be so overwhelming. His personal issues
in relation to stress have been resolved satisfactorily in relation to contact
with his daughter; now if anything having been not only facilitated but vastly
enhanced. Mr Horne concluded by asking should a moment of madness, brought on
by significant professional and personal stress, be the end to his career in
NHS practice.
17. Our Conclusions
We
were addressed by both advocates; both orally and in the terms of skeleton
arguments produced as to the burden and standard of proof and that the hearing
would fall to be a re-determination of the matter. Therein we agree. We were also addressed as to this being an
appeal where there is now only issue standing in relation to suitability under
Regulation 6(1)(a) and, as such, there would be no provision for us to impose
any conditions if allowing Dr Sinha’s appeal.
Therein we agree also.
18. We also noted that one of the primary considerations to be
applied in our deliberation would be the protection of patients. Indeed, protection of patients should be the
overriding consideration when considering whether an Appellant should be
admitted to a list. Applying the tests
enunciated earlier we found that the Appellant's conduct in relation to the
incidents of assault; both occurring at the same time, were unprofessional and
inappropriate, regardless of the circumstances of which the Appellant found
himself in. It was clear, however, on
the available evidence before us that this was, as has been submitted on behalf
of the Appellant, a momentary aberration, especially when one sets it in to the
context of the Appellant's previous unblemished clinical history, the absence
of any complaints from patients. There is no doubt, as was brought to our
attention, that the pressures placed upon the Appellant in the performance of
his duties with such a high number of patients with only locum assistance,
would bring about a significant work load, and indeed a most stressful one as
has been outlined to us. Further, it is
also clear that the Appellant was subject to stress in relation to an ongoing
contact dispute concerning his daughter.
19. It is clear to us, with the passage of time, that the
Appellant is well aware of the extent to which his behaviour on that occasion
fell well below that required of him. We did not set any weight to the other
matters arising in the CRB report; they were clearly unsubstantiated when
tested. We have heard how long the jury took to dismiss one matter, of the time
between incident and complaint, and in the other matter that the Appellant was
completely exonerated; we attach no weight to them. We have, through the course of the hearing, had an opportunity of
observing and noting the demeanour of the Appellant at the hearing. We have
also heard evidence from Dr Fink concerning his input with the Appellant. We also noted, whilst it was for us to make
our own decision, that it was clear that the GMC noted the Appellant's remorse
and apology for his behaviour. We did
not find, taking into account information given to us as regards the
Appellant's means at the time of the hearing; that the fine was at such level
that the Appellant should not be admitted to the list. It was clear that far
from increasing penalty, the sentencing court, presumably properly advised by a
qualified Legal Advisor departed from Sentencing Guidelines and imposed a
lesser penalty, a fine. We found the evidence of Mr Harrop in relation to his
interpretation of the same unhelpful; and, further clearly in error, when
giving consideration to the level of costs imposed, as being an indicator of
seriousness in itself.
20. We find that there has been a sufficient length of time since the
offence for the Appellant, who we feel has given genuine and credible evidence
as regards his future intentions to deal with issues of stress, and to have
reflected fully on all the circumstances leading to this hearing. We find that the PCT has not, against the
appropriate standard, satisfied us that the Appellant is unsuitable for
inclusion in the performers list. We allow this appeal.
21 Appeal Allowed.
……………………
Mr T Jones, Chairman
23rd February 2005
Either party to these proceedings has the right to appeal this decision
under and by virtue of Secretary of State. II Tribunals and Inquiries Act 1992.