Pre hearing information
The tribunal will inquire into the allegation that by a letter dated 28 November 2017, Dr Tirupur Shanmugasundaram Ramakrishnan and Dr A, responded to a patient complaint in the name of their colleague Dr B stating that Dr B had led the investigation into the patient’s complaint, read the patient’s concerns, reviewed the patient’s records and held discussions with the colleagues involved. It is alleged that Dr Tirupur Shanmugasundaram Ramakrishnan knew that Dr B had not carried out these activities and that his conduct was therefore dishonest.
It is also alleged that on 28 November 2017, Dr Tirupur Shanmugasundaram Ramakrishnan submitted an email to NHS England on behalf of himself and Dr A, which attached a copy of the letter dated 28 November 2017. It is alleged that Dr Tirupur Shanmugasundaram Ramakrishnan sent this letter having falsified Dr B’s electronic signature and knowing that it was sent without Dr B’s knowledge of the content of the letter, permission to use his signature or consent. It is alleged that his actions were dishonest.
It is further alleged that on or around 29 November 2017, Dr Tirupur Shanmugasundaram Ramakrishnan provided Dr B with a copy of this letter, knowing that it was not the exact copy emailed to NHS England, in that it did not contain Dr B’s electronic signature. It is alleged that his conduct was dishonest.
The tribunal will also inquire into the allegation that on or around 6 December 2017, Dr Tirupur Shanmugasundaram Ramakrishnan advised Dr B words to the effect that he should not discuss the matter with the Medical Defence Union and feign a lapse in memory if NHS England questioned him about the matter. It is alleged that he knew his conduct was inappropriate in that it was encouraging Dr B to act dishonestly.
It is also alleged that on 6 December 2017, Dr Tirupur Shanmugasundaram Ramakrishnan sent an email to NHS England stating that Dr B had collated the responses from those involved and drafted the letter when he knew that Dr B had not carried out these activities. It is alleged that his actions were dishonest.
This reflects the allegation as it stands at the start of the hearing. The allegation may be amended as the hearing proceeds and when findings of fact are made by the tribunal.
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