BY EMAIL FOA Disciplinary Committee
From the family
of baby Sunaina Chaudhari (deceased)
28 April 2009
Disciplinary Committee
c/o Aneta Pszczola
Corporate and Strategic Development
Directorate
Royal Pharmaceutical Society
of Great Britain
1 Lambeth High Street
SE1 7JN Fax 0207 572 2510
(Tel 0207 572 2618)
Dear Disciplinary Committee
c/o Aneta Pszczola,
Re: URGENT
Royal Pharmaceutical Society
of Great Britain V Neelu Chaudhari
A. Medical Expert Report
– Baby Sunaina, B. RPSGB Disclosure, C. Witnesses, D. Racial Discrimination and Victimisation E. Unfair Trial and conflict
of interests, F. Perverse Decisions, Procedural Bias & Legal ambush G. Perverting the course of justice
A(1) Fresh evidence 142
page Medical Expert Report
The family of baby Sunaina
hereby submit the 30 page attachments to accompany the fresh evidence 142 page Expert Medical Report dated May 2001 by Medical
Investigations UK, in respect of the care provided to baby Sunaina Chaudhari (deceased) prior to her death on 26 October 2000
detailing evidence of breaches of the Human Rights Act 1998, the European Convention on Human Rights articles 1, 2, 3, 5,
6, 7, 8, 9, 10,11,13 & 14, and Part III (60) of the Health Act 1999. It is
for the urgent attention of the Disciplinary Committee:-
Art.1: Obligation to respect
human rights of the Chaudhari family, particularly Ms N & Ms S Chaudhari
Art.2 : Right to life of baby Sunaina Chaudhari
Art.3 : Prohibition of
torture of baby Sunaina Chaudhari and her family, particularly Ms N & Ms S Chaudhari
Art.5 : Right to liberty
and security of baby Sunaina Chaudhari and her family
Art.6 : Right to a fair
trial into the death of baby Sunaina Chaudhari
Art.7 : No punishment
without law of the Chaudhari family, particularly Ms N & Ms S Chaudhari
Art.8 : Right to respect
for private and family life of baby Sunaina Chaudhari and her family,
particularly Ms N & Ms S Chaudhari
Art.9 : Freedom of thought,
conscience and religion of the Chaudhari family, particularly Ms N Chaudhari
Art.10 : Freedom of expression
of the Chaudhari family, particularly Ms N & Ms S Chaudhari
Art.11 : Freedom of assembly
and association of the Chaudhari family,
Art.13 : Right to an effective
remedy of baby Sunaina Chaudhari and her family
Art.14 : Prohibition of
discrimination of baby Sunaina Chaudhari and her family
Health Act 1999 CHAPTER
8
Part III Miscellaneous
and Supplementary
60 Regulation of health
care and associated professions
(1)
Her Majesty may by Order in Council make provision—
(a) modifying the regulation
of any profession to which subsection (2) applies, so far as appears to Her to be necessary or expedient for the purpose of
securing or improving the regulation of the profession or the services which the profession provides or to which it contributes,
(b) regulating any
other profession which appears to Her to be concerned (wholly or partly) with the physical or mental health of individuals
and to require regulation in pursuance of this section.
(2)
The professions referred to in subsection (1)(a) are—
(a) the professions
regulated by the [1954 c. 61.] Pharmacy Act 1954, the [1983 c. 54.] Medical Act 1983, the [1984 c. 24.] Dentists Act 1984,
the [1989 c. 44.] Opticians Act 1989, the [1993 c. 21.] Osteopaths Act 1993 and the [1994 c. 17.] Chiropractors Act 1994,
(b) the professions
regulated by the [1997 c. 24.] Nurses, Midwives and Health Visitors Act 1997,
The family first complained
to the professional bodies against pharmacists, doctors and nurses, on 11 December 2002, 23 July 2001, and 2003 respectively,
detailing the drug overdoses prescribed, dispensed and administered to baby Sunaina.
The family then complained
to the Royal Pharmaceutical Society of Great Britain against Pharmacy Inspector Mr Martin Ibbitt due to delays and ineffective
investigation.
The family then complained
to the Royal Pharmaceutical Society of Great Britain for failing to investigate their complaint against Mr Martin Ibbitt’s
failure to investigate the family’s complaint. The Royal Pharmaceutical
Society of Great Britain then invented an Inquiry against the Practitioner after secret communications with General Medical
Council, attached, Exhibit A & Exhibit B, details below.
The chronology of events
presented by the Royal Pharmaceutical Society of Great Britain Mr Tom Rider, Field Fisher Waterhouse before the Disciplinary
Committee omits the relevant and pertinent facts of the background of the complaints made by the family in respect of the
death of baby Sunaina, including the compilation of the Expert Report by Ms Neelu Chaudhari dated 24 March 2004 which led
to the Inquiry against a family member, a pharmacist, a witness a professional and an Expert.
The Royal Pharmaceutical
Society of Great Britain has concealed the file of the investigation by Mr Martin Ibbitt and its investigation of the complaint
by the family against Mr Ibbitt. The fact that Mr Ibbitt was involved in the
investigation into the drug overdoses much earlier than the family’s complaint dated 11 December 2002 has also been
omitted.
The Royal Pharmaceutical
Society of Great Britain’s Mr Tom Rider, Field Fisher Waterhouse, objection to the fresh evidence being submitted to
the Disciplinary Committee is to continue to conceal the truth, misrepresent the facts and pervert the course of justice into
the death of baby Sunaina.
Two medically qualified doctors
first made criminal allegations against NHS staff, doctors, nurses, paediatricians, pathologists, Police, freemasons, and
NHS hospitals in the 28 emails sent to the family during March and April 2001.
Their recommendations, see
p105-109 of the 142 page Medical Report, summarise as follows:-
· “A New investigation which a police team is required as there are many elements
of a criminal nature.
· An Independent coroner to be appointed or the inquest held at a different court. This
is in line with Article 6 of the Human Rights Act 1998
· All documents are required to be seized under PACE immediately from the Social Services,
Great Ormond Street and King Georges Hospital
· Further questioning and inquiries are required before the inquest is carried out. We would refer this case to a full inquiry due to the number of individuals involved and the complexities.
· It is imperative that the relationship between the police and the family is reinstated
The interests of a dead child is served well by the justice system of the United
Kingdom.”
The two Experts suggest the
family take the following avenues:-
a) “Presentation of
this document to Scotland Yard and the Home Office in London
b) Commencement of NHS Complaints
Procedure to the NHS Health Ombudsman
c) Commencement of Social
Services Complaints Procedure
d) Civil Litigation to be
pursued to the European Courts
e) Criminal Litigation”
The evidence in the 142 page
Medical Expert Report formed the basis of the Legal Report “Who Killed Baby Sunaina?”, also in May 2001, and later
the book “Gigantic perversions of Justice” compiled by Free Human Rights Lawyers, for which the family are being
punished.
No libel action has been
brought by any doctor, hospital or NHS Trust against the family, the two medical Experts, the Free Human Rights Lawyers or
any member of the family.
The evidence in the 142 page
Medical Expert Report condemns the ex-parte Emergency Protection Order application by the doctors, social services and hospital,
against the parents of baby Sunaina, alleged to bring the profession of pharmacy into disrepute.
The evidence in the 142 page
Medical Expert Report condemns the actions of several medical doctors, including paediatricians from the King George Hospital
who are employed by the Barking Havering & Redbridge NHS Trust, applicant in an ex-parte injunction against the mother
of baby Sunaina, alleged to bring the profession of pharmacy into disrepute.
The evidence in the 142 page
Medical Expert Report condemns the actions of the paediatricians from the Great
Ormond Street Hospital
for sick Children who are the applicants in an ex-parte injunction against the mother of baby Sunaina, alleged to bring the
profession of pharmacy into disrepute.
A(2) Evidence that GMC
instigated the Inquiry on 09 August 2004 to avoid investigating doctors, see Exhibit A
The family hereby submit
fresh evidence dated 09 August 2004, attached Exhibit A, a page taken from the General Medical Council file of the investigation
into the family’s complaint made on 23 July 2001 against 22 doctors.
General Medical Council caseworker
Michael Hudspith writes to the General Medical Council screeners on 09 August 20004:-
“Memorandum
Ref 2004/0597
To: Peter Lynch
From: Michael Hudspith, 0207915 3617
Date 9 August 2004
“Sunaina Chaudhari (deceased):-
“I attach a letter received recently from one of the co-complainants, Mrs Berry, the contents of which is self explanatory.
Mrs Berry has forwarded with her letter a previously
unseen “expert report” (prepared by herself).
“Am I right in assuming that this report technically constitutes new evidence? So, would it be appropriate to disclose it to the original screeners to review and take a view over whether
its contents would require them to change their screening decisions?
“For information, I have checked Mrs Berry’s
registration with the RPSGB. She is registered with them although in 2000 she
signed an undertaking not to practice due to ill health. I am in the process
of establishing whether Mrs Berry has any FTP/Health “history”
with the RPSGB.
“With regard the reference to an ongoing police investigation, I have spoken to DI Carl Tipping of the Metropolitan
Police case review unit. Mrs Berry
recently wrote to New Scotland Yard with a list of about 30 complaints. The Police
discounted all as being not matters for them with the exception of an alleged over prescribing of ranitidine. This issue has been referred back to their expert (blanked out [professor Weindling]) for opinion”
The above evidence suggests
that it was the General Medical Council, which instigated the Fitness to Practice proceedings against Ms Neelu Chaudhari on
09 August 2004, to disorientate potentially serious and widespread investigations into 22 doctors following the suspicious
death of an Asian baby.
After being confronted with
Ms Neelu Chaudhari’s Expert Report dated 24 March 2004, Professor Weindling, in his second report dated 15 August 2004,
finally admitted that mistakes had been made by doctors, pharmacists and nurses (after having wrongly stated in his earlier
report dated 27 December 2000 and during his oral evidence before the Inquest jury on 11 September 2001, that the care given
to baby Sunaina was of an exceptionally high standard).
A(3) Evidence that RPSGB
instigated the Inquiry on 21 October 2004 to avoid investigating pharmacists, see Exhibit B
The Royal Pharmaceutical
Society of Great Britain instigated the Disciplinary action against Ms Neelu Chaudhari on 21 October 2004, see attached Exhibit
B:-
After Ms Neelu Chaudhari’s
submitted her Expert Report dated 24 March 2004 to the General Medical Council
After the General Medical
Council’s secret communication with Detective Inspector, Serious Crime Directorate, Carl Tipping, on 09 August 2004,
in which the Police expressed concerns about the ranitidine overdoses detailed in Ms Neelu Chaudhari’s Expert Report
After publication of
Professor Weindling’s second Expert report dated 15 August 2004 in which he admitted that doctors, wrongly prescribed,
pharmacists, wrongly dispensed and nurses, wrongly administered, ranitidine drug overdoses to baby Sunaina continuously over
the period between 26 September 2000 and her death on 26 October 2000
The Royal Pharmaceutical
Society of Great Britain and the General Medical Council conspired together to instigate the Inquiry against Miss Neelu Chaudhari
to avoid investigations into complaints, made by an Asian family following the death of an Asian baby, against doctors, pharmacists
and nurses thus failing to carry out their statutory functions of regulating their professions, putting the physical and mental
health of the public at risk, thereby breaching the Health Act 1999 (see below).
The Royal Pharmaceutical
Society of Great Britain and the General Medical Council, thereby jointly discriminated against the family and victimised
the family.
The Royal Pharmaceutical
Society of Great Britain and the General Medical Council jointly conspired to prejudice the Police criminal investigation
by instigating the disciplinary action against a member of the family who is a pharmacist, discriminating against and victimising
an Asian baby (deceased), an Asian pharmacist and an Asian family contrary to Article 1 and 2 of the European convention on
Human Rights.
The conduct of General Medical
Council and Royal Pharmaceutical Society of Great Britain to persist to defy its Statutory function by punishing bereaved
complainant family constitutes inhuman treatment, torture and degrading treatment of baby Sunaina and the family particularly
of pharmacist Ms Neelu Chaudhari.
B(1) Disclosure of contents
of Neelu Chaudhari personal file to Neelu Chaudhari
Ms Neelu Chaudhari has requested
a copy of her personal file, held at Royal Pharmaceutical Society of Great Britain but this has been refused. The refusal is a breach of Article 6 and 13 of the European convention on Human Rights, unfair trial, unfair
procedure and inequality of arms in the investigation into the death of baby Sunaina.
B(2) Disclosure of contents
of the RPSGB file into the family’s complaint to the Disciplinary Committee
The Chairman stated that
he could not direct that the Royal Pharmaceutical Society of Great Britain to disclose the copy of the file into the family’s
complaint under the Freedom of Information Act, yet the General Medical Council has provided a copy of the file of its investigation
into the family’s complaint against 22 doctors under that Act.
The Chairman ought to have
requested that the Royal Pharmaceutical Society of Great Britain discloses the file of its investigation into the family complaints
to the Disciplinary Committee.
By instigating the fabricated
Inquiry against Ms Neelu Chaudhari, in a conspiracy, the professional bodies are punishing the complainant family, abusing
its powers as a public authority, in self-regulation, to mislead the courts and the Committee into believing there were unnecessary
delays, when in fact these were deliberate omissions to avoid investigation and fail to regulate the profession without regard
to the physical and mental health of the Asian family.
C(1) No Witnesses called
– Mr Martin Ibbitt refuses to come
No witness has been called
by the Royal Pharmaceutical Society of Great Britain in its Inquiry against Ms Chaudhari.
No complainant has been identified. No specific date or time has been
given when the complaint was made or arose. The only significance of the date
when the Inquiry against Ms Chaudhari was commenced, namely 15 February 2007, is that the family was in receipt of legal action
by the London Borough of Redbridge, also dated 15 February 2007, giving the family 28 days to do a funeral, on the body of
baby Sunaina, otherwise the local authority would do so. The family suspect that
the professional bodies conspired with the London Borough of Redbridge to destroy the body of baby Sunaina.
This is a formal request
that the Disciplinary Committee calls Mr Martin Ibbitt to come as witness and for the Disciplinary Committee to peruse the
file of his investigations into the family’s complaint and the investigation into the family’s complaint against
him.
It is noted that no pharmacist
clinical experts at the Society’s headquarters have found any fault in Ms Neelu Chaudhari’s Expert reports or
discounted her conclusions.
All the allegations and assertions
made by Ms Neelu Chaudhari are included in her Expert Reports.
The remainder of the allegations
complained about, in the Inquiry against Ms Neelu Chaudhari, originate from Medical Experts.
C(2) Witnesses to be called
– Dr Rita Pal & Dr Rani Pal
This is a request for the
Committee to call Drs Rita Pal and Dr Rani Pal.
D Racial Discrimination
and Victimisation
The Royal Pharmaceutical
Society of Great Britain first notified Ms Neelu Chaudhari of the Inquiry against her on 15 February 2007, the date on which
the two pharmacists responsible for dispensing the drug overdoses, were let off by the Infringement Committee on the excuses
put forward by the Royal Pharmaceutical Society of Great Britain, namely “length of time of over 4 years elapsed”
“unable to identify those responsible”. The details of the Inquiry
against Ms Neelu Chaudhari were still increasing in 2008, despite the events complained about having occurred in 2000, 2002,
2003 and 2004, over four years earlier.
Mr Tom Rider and Field Fisher
Waterhouse would have the Committee believe that there is no connection between the investigations into the death of baby
Sunaina and the fabricated Inquiry against Ms Neelu Chaudhari. Clearly the evidence
suggests otherwise, namely, that the Inquiry against Ms Neelu Chaudhari was commenced because she complained about the care
provided to her baby neice, who was Asian and because she, herself is Asian.
Her family is being punished
because they complained about breaches of their Human Rights and those of an Asian baby because an Asian life is considered
by the professional bodies not worth investigating. As an Asian pharmacist,
she is punished for exercising her opinion and expertise to challenge British public authorities, as she is trained to do,
as a professional pharmacist. She is denied her rights to a family member, her freedom of expression, her expertise, her beliefs,
her profession and her livelihood because the professional bodies choose not to investigate the family’s complaints,
but to punish the family. The family is punished by this Inquiry against a family
member who is a pharmacist. She is punished for her professional actions at the
highest integrity and probity, upholding the reputation of the pharmacy profession at the ultimate level. Her opinion is truthful, accurate and credible, such that no other pharmacist or medical professional has
challenged it. Her opinion has caused a professor paediatrician to not only change
his opinion but to contradict himself.
In particular, no explanation
has been provided why the Royal Pharmaceutical Society of Great Britain instigated this Inquiry in 2007, at the same time
as the two pharmacists who had been complained about by the family over 4 years earlier.
A legitimate and credible
complaint by a victim family is being mocked and ridiculed by the Royal Pharmaceutical Society of Great Britain in an abuse
of power and an abuse of process of law against a family member because she is a pharmacist member.
The failure of the Royal
Pharmaceutical Society of Great Britain jointly with the General Medical Council to investigate any pharmacist, employer,
doctor or nurse for the dispensing, prescribing and administration of ranitidine drug overdoses for Asian baby Sunaina in
the 4 week period prior to her death, constitutes racial discrimination and victimisation against the Asian baby and her Asian
family.
This is also a formal request
that the Race Relations Questionnaire submitted to the Royal Pharmaceutical Society of Great Britain in 2007 be completed
and a copy be provided to the Disciplinary Committee for its consideration as soon as possible.
E. Unfair Trial and conflict
of interests,
The family wish to point
out the conflict of interest with the appointment, by the Royal Pharmaceutical Society of Great Britain, of Mr Tom Rider and
Field Fisher Waterhouse, who also act for the General Medical Council, responsible for ineffective investigation into the
family’s complaint against 22 medical doctors and for instigating the Inquiry against Ms Neelu Chaudhari. The family is being punished for making a complaint to the General Medical Council, by being racially discriminated
against and victimised by the Royal Pharmaceutical Society of Great Britain.
F. Perverse Decisions,
Procedural Bias & Legal ambush
On 9th, 10th
11th February 2009 the Chairman ought to have stepped down given that he has been accused of unfairness and bias. After deciding on his own, to sit alone, and have an oral hearing in Private for a
SI 1978/20 section 10 application, rather than allow the Committee to make the decision, the Chairman has not explained why
he sat in private to decide on paper.
The Chairman’s decision
to proceed with the Inquiry despite the Practitioner’s ill-health constitutes bias, racial discrimination and victimisation
against the Practitioner.
The proceedings on 9th,
10th 11th February 2009 are evidence of an unfair trial, inequality of arms, ineffective trial and legal
ambush during the Practitioner’s ill health.
The Royal Pharmaceutical
Society of Great Britain’s lawyers have taken advantage of the Practitioners ill health by proceeding with the Inquiry
in the absence of her defence, skeleton argument, legal representation and presence.
G. Perverting the course
of justice
The Royal Pharmaceutical
Society of Great Britain’s objection to the disclosure of the contents of the 142 page Medical Expert Report to the
Disciplinary Committee, its refusal to disclose key documents in two files it holds (see B(1) & B(2) above), and concealment
of material facts and evidence is to continue to pervert the course of justice in an unfair, bias, ambushed, fabricated Inquiry.
It is bizarre that the Royal
Pharmaceutical Society of Great Britain is silent on the failings of the clinical pharmacy services provided to baby Sunaina,
by the pharmacy department at King George Hospital, despite its extensive powers and resources to effectively and thoroughly
investigate, serious complaints such as those made by the family, not just against individual pharmacists, but against employers
and bad practices. The Royal Pharmaceutical Society of Great Britain experts
are also misleading the Disciplinary Committee by being silent and absent as witnesses in the Inquiry for fear that they may
be challenged by the truth.
Mr Martin Ibbitt is silent
on the incident on 05 October 2000, when a bottle of ranitidine syrup was found on the hospital children’s ward, with
baby Sunaina’s name on the label showing an adult dose, “Two 5 ml [10ml] spoonfuls to be taken twice daily”
instead of “0.2mls to be given three times daily”. An incident form
was completed, but no information has been provided to the family as to what interventions the hospital pharmacist made on
the Incident form. The absence of Mr Martin Ibbitt and his silence as witness
is to pervert the course of justice into the death of baby Sunaina Chaudhari. Mr
Ibbitt is equally absent and silent on the complaint against Tesco as an employer.
This is a formal request
that Tesco and the pharmacy department at King George Hospital, as pharmacy employers, are
investigated by the Royal Pharmaceutical Society of Great Britain for bad clinical audit practices, in failing to identify
the responsible pharmacists.
The above Inquiry instigated
by the Royal Pharmaceutical Society of Great Britain and the General Medical Council to obstruct investigations into the death
of an Asian baby is in breach of Section 60 of the Health Act 1999 and in breach of articles 1, 2, 3, 5, 6, 7, 8, 9, 10, 11,
13 and 14 of the European Convention on Human Rights and the Race Relations Act
1976.
Ms S Chaudhari hereby submits
letters she sent to senior public officials at the Royal Pharmaceutical Society of Great Britain which have been ignored as
a result of the fabricated Inquiry against Ms Neelu Chaudhari, see Exhibits C & D .
The investigation of a complaint
of drug overdoses prior to the suspicious death of baby Sunaina cannot fairly or lawfully be obstructed by a fabricated Inquiry
into a family member by public bodies which are the subject of the complaint by that family in a democratic society.
Yours sincerely
What is stated above is true,
The family of baby Sunaina
Chaudhari
