Probity Concerns in Healthcare: Common Examples and How They Arise
Five real UK court cases across doctors, nurses, paramedics and dentists, from altered certificates to falsified medication records, examined as case files. What happened, how the concern arose, what the regulator and the courts decided, and the patterns that turn ordinary pressures into career-ending probity cases.
Short answer: common probity concerns in UK healthcare include falsified or altered records, dishonest job applications and CVs, altered or misrepresented registration documents, false financial or insurance claims, working elsewhere while on sick leave, and covering up a mistake. Most arise from ordinary pressures: panic after an error, the wish to get a job, money worries or a shortcut that seemed harmless. Real cases show a consistent pattern. When dishonesty is proved, the outcome is often erasure or striking off, and the courts have replaced sanctions they considered too lenient.
Key takeaways
- Probity cases reach every profession: the cases below involve doctors, a nurse, a paramedic and a dentist.
- Cover-ups after a mistake turn a clinical concern into a probity case.
- The GMC and PSA have successfully appealed suspensions in dishonesty cases, leading to erasure or striking off.
- Repeated misconduct and broken assurances weigh heavily against the professional.
- Correcting an error openly, early and in writing is the most effective protection.
This article builds on our pillar guide to probity in healthcare, which explains the standards and the legal test for dishonesty. Here, the focus is on real cases: what probity concerns actually look like, and how they arise.
How probity concerns arise: five pathways
Very few healthcare professionals set out to be dishonest. Looking across reported cases, most probity concerns follow one of five recognisable pathways.
Panic after a mistake
An error happens, fear takes over, and the response is to hide it: a record filled in later, a denial, a story that does not match the facts.
Career pressure
Wanting a job or promotion leads to exaggerated experience, inflated job titles or altered documents.
Financial pressure
Money worries lead to false claims: insurance, expenses, timesheets or fees.
Shortcuts
Something that feels harmless or convenient, such as working a locum shift while signed off sick, without telling anyone.
Blurred boundaries
Gifts, favours and personal interests that slowly influence decisions, without being declared.
Understanding which pathway a concern followed matters. It is central to insight, and it shapes what meaningful remediation looks like.
Case files: five real probity cases
Each case below is a published court judgment. Read together, they show how differently probity concerns begin, and how similarly they tend to end.
GMC v Theodoropoulos [2017] EWHC 1984 (Admin)
What happened. A consultant ophthalmologist accessed his GMC registration certificate, which showed he was registered without a licence to practise. He altered it to read “with a licence to practise” and sent it to a recruitment agency to obtain work he was not eligible for.
What was decided. The tribunal found his fitness to practise impaired and suspended him for 12 months. The GMC appealed. The High Court quashed the suspension and directed erasure, holding that his conduct affected the integrity of the system of qualifications and job applications.
What it teaches: dishonesty about your registration or eligibility to practise strikes at the heart of regulation, whether or not any patient was involved.
Abdulhamid v GMC [2025] EWHC 62 (Admin)
What happened. A doctor applying to an NHS trust claimed his previous posts were in urology, when they were in ENT and trauma and orthopaedics. He repeated the misrepresentation at interview.
What was decided. The tribunal found the dishonesty persistent and deliberate, with risks to patient safety, and erased him in February 2024. In January 2025, the High Court dismissed his appeal and upheld the erasure.
What it teaches: misrepresenting experience is not a minor embellishment. It can put patients at risk, because employers rely on it to decide what work you are safe to do.
Related courseProbity: honesty in applications, CVs and interviews→PSA v NMC and Tchampet [2026] EWHC 141 (Admin)
What happened. A nurse providing one-to-one care to a ventilated ten-year-old covered a CCTV camera, slept for nearly four hours, and falsified the child’s observation records. She denied sleeping for six weeks before admitting it. She had previously received a formal warning for sleeping on duty while caring for another vulnerable patient.
What was decided. An NMC Fitness to Practise Committee imposed a nine-month suspension. The Professional Standards Authority appealed, arguing it did not protect the public. On 30 January 2026, the High Court quashed the suspension and substituted a striking-off order, pointing to the repeated misconduct despite the earlier warning, the sustained dishonesty, the breach of the duty of candour and the vulnerability of the patient.
What it teaches: falsified records combined with denial during an investigation is among the most serious patterns. Previous warnings and broken assurances count heavily.
Related courseDuty of Candour: being open instead of covering up→Hough v HCPC [2026] EWHC 743 (Admin)
What happened. An advanced paramedic with 30 years’ experience was found to have committed serious misconduct across two incidents. Most significantly, during a cardiac arrest he recorded that he had given midazolam when he had not. The record concealed that he had improperly delegated the drug to an unqualified colleague.
What was decided. The HCPC’s Conduct and Competence Committee struck him off, finding dishonesty and only limited insight. On 27 March 2026, the High Court dismissed his appeal. It accepted that the panel had considered his long career and testimonials, but agreed that his limited insight left a significant risk of repetition.
What it teaches: a single false entry, made to cover another failing, can outweigh decades of good practice. Long service and testimonials do not offset limited insight into dishonesty.
Related courseRecord Keeping: accurate entries, especially under pressure→Kirschner v GDC [2015] EWHC 1377 (Admin)
What happened. A dentist split single courses of NHS treatment for three child patients into two separate claims, submitting the second after more than 62 days. The extra claims totalled £144.
What was decided. The GDC’s Professional Conduct Committee found her dishonest and suspended her for a year. The High Court quashed the dishonesty findings, because the committee had found both that she had persuaded herself splitting was acceptable and that she knew the claims were not allowed. The judge called that combination impossible to reconcile, and sent the case back for sanction without the dishonesty findings.
What it teaches: what you genuinely believed about the rules matters, and decision-makers must reason consistently. This case was decided under the old Ghosh test. Under today’s Ivey test, your genuine belief about the facts is still the first question, but whether you realised the conduct was dishonest no longer is. Small sums do not prevent a claims issue from becoming a fitness to practise case.
Related courseFinancial Integrity: getting claims and fees right→Side by side: what decided these cases
| Case | Concern | First outcome | Final outcome | Deciding factor |
|---|---|---|---|---|
| Theodoropoulos (2017) | Altered registration certificate | 12-month suspension | Erasure, on GMC appeal | Damage to the integrity of qualifications and recruitment |
| Abdulhamid (2025) | False experience on job application | Erasure | Erasure upheld | Persistent, deliberate dishonesty with patient safety risk |
| Tchampet (2026) | Falsified records and denial | 9-month suspension | Striking off, on PSA appeal | Repetition after a warning, sustained dishonesty, vulnerable patient |
| Hough (2026) | False medication record | Striking off | Striking off upheld | Dishonesty to conceal another failing, with limited insight |
| Kirschner (2015) | Split NHS dental claims | 1-year suspension, dishonesty found | Dishonesty findings quashed, sanction reconsidered | Inconsistent findings about what she believed |
Three patterns stand out. First, in two of these cases a suspension was replaced with the most severe sanction after an appeal by the GMC or the PSA, both of which can challenge decisions they consider insufficient to protect the public. Second, in all four cases where dishonesty was upheld, the end result was erasure or striking off. Third, Kirschner shows the other side: where a panel’s reasoning about what someone believed does not hold together, a dishonesty finding can be overturned.
Probity for Healthcare Professionals
The standards behind honesty in records, applications, declarations and finances, and how to recognise the pathways that lead to a probity concern before they start. Assessed, with a CPD certificate.
Completing a course does not change or predict any regulator’s decision. Courses are educational and support your own reflection and development.
Other common probity concerns
Beyond the cases above, these are other examples of probity concerns that regulators regularly consider:
| Example | Why it raises a probity concern |
|---|---|
| Signing off care or checks you did not carry out | Creates a false record that others will rely on. |
| Claiming hours or expenses not worked or incurred | Financial dishonesty with an employer or the NHS. |
| Not declaring a caution, charge or conviction | Breaches duties to tell your regulator and employer. |
| Answering a registration or revalidation question inaccurately | A false formal declaration to your regulator. |
| Writing a reference you know is misleading | Misleads an employer about a colleague’s safety or suitability. |
| Accepting gifts or hospitality that influence prescribing or referrals | An undeclared conflict of interest. |
| Misusing patient or NHS resources for private benefit | Abuse of a professional position. |
| Fabricating or manipulating audit or research data | Undermines the evidence that care depends on. |
Early warning signs in your own practice
Most probity concerns can be stopped before they start. Treat these thoughts as warning signs:
- “I’ll write the notes up properly later, and nobody will know they were late.”
- “It’s basically the same job, so I’ll call it that on my CV.”
- “I’m off sick from there, but this shift is a different employer.”
- “If I admit this now, it’ll make things worse.”
- “Everyone accepts gifts like this.”
The real cases above show where each of these thoughts can lead.
If you realise you have made a probity mistake
The difference between a mistake that is corrected and one that is discovered is often the difference between a manageable concern and a serious one.
- Stop, and do not make it worse. Do not alter records further, delete messages or give inaccurate explanations.
- Take advice from your defence organisation, union or professional body.
- Correct the record openly, with a clearly dated and attributed correction, following your employer’s process.
- Tell the people who need to know, such as your manager, employer or regulator, as your standards require.
- Reflect honestly on which pathway led you there, and what you will do differently.
Our guides on responding to a concern, writing a reflective account and remediation evidence explain the next steps in detail.
Frequently asked questions
What are examples of probity concerns in healthcare?
Common examples include falsified or altered records, dishonest job applications or CVs, altered registration documents, false insurance or expense claims, working elsewhere while on sick leave without telling your employer, failing to declare cautions or convictions, and covering up mistakes.
Can a probity concern end my career if no patient was harmed?
Yes. In Theodoropoulos and Abdulhamid, the dishonesty related to a registration document and a job application rather than direct patient harm, and both ended in erasure. Our probity guide covers another example, a false insurance claim in GMC v Hayat.
Is covering up a mistake worse than the mistake itself?
Often, yes. In Tchampet, falsified records and weeks of denial during the investigation were central to the High Court substituting striking off for suspension.
Can a regulator’s decision be made harsher on appeal?
Yes. The GMC can appeal tribunal decisions, and the Professional Standards Authority can refer decisions it considers insufficient to protect the public. In Theodoropoulos and Tchampet, suspensions were replaced with erasure and striking off.
Does a previous warning matter?
It can matter a great deal. In Tchampet, the court gave significant weight to an earlier warning for similar conduct and to assurances that had not been kept.
Is exaggerating my experience on a CV a probity issue?
Yes. In Abdulhamid, misrepresenting previous posts on an application and at interview led to erasure, which the High Court upheld.
What should I do if I realise I have made a probity mistake?
Do not make it worse, take advice, correct the record openly and properly, tell the people who need to know, and reflect honestly on how it happened.
Are all probity concerns about dishonesty?
No. Some involve failures of openness or integrity, such as undeclared conflicts of interest, without a finding of dishonesty. But dishonesty findings are the most serious.
Do long service and good testimonials protect against a dishonesty finding?
Not necessarily. In Hough (2026), a paramedic with 30 years’ experience was struck off for a false medication record, and the High Court upheld it because his limited insight left a significant risk of repetition.
Primary sources
- GMC v Theodoropoulos [2017] EWHC 1984 (Admin), National Archives
- Abdulhamid v General Medical Council [2025] EWHC 62 (Admin), National Archives
- PSA v NMC and Tchampet [2026] EWHC 141 (Admin), National Archives
- Professional Standards Authority: Section 29 appeal powers in practice, PSA v NMC and Tchampet
- Hough v HCPC [2026] EWHC 743 (Admin), National Archives
- Kirschner v General Dental Council [2015] EWHC 1377 (Admin), National Archives
- MPTS: Guidance for MPTS tribunals (in effect from 24 November 2025)