Doctor struck off for prescribing steroids

Date: June 16, 2017


Medical Board of Australia v Singh [2017] WASAT 33


Key Points


Dr Singh was a registered practitioner practicing as a general physician in Western Australia. He had been practicing medicine for 25 years. Allegations were made against him relating to two specific patients, and also his practice more generally, in prescribing drugs and treatments where there was no therapeutic basis for doing so. Specifically, Dr Singh was alleged to have prescribed androgen anabolic steroids and related drugs for weight loss, physical conditioning and body building. Disciplinary proceedings were commenced by the Medical Board of Australia.

Dr Singh conceded that he prescribed various anabolic steroids, clenbuterol and ephedrine to patients who presented to him seeking weight loss and physical conditioning. The main issue in contention was whether the drugs provided by Dr Singh had any therapeutic basis. Dr Singh contended that there was in fact therapeutic basis for prescribing the drugs in question and there were no adverse effects associated with them. A range of expert evidence was considered in relation to the therapeutic basis and adverse effects of the drugs prescribed. Various experts agreed that there were no therapeutic indications for the prescription of anabolic steroids, clenbuterol or ephedrine.

The Board also alleged that Dr Singh did not make adequate notes or written record as to his consultation and treatment of patients. Most importantly, Dr Singh failed to document the adverse symptoms of the drugs and treatments prescribed by him. Dr Singh initially denied that his records were inadequate but during the course of the hearing conceded on this point.

The Law

The Tribunal found that Dr Singh acted carelessly, incompetently and/or improperly under the Medical Practitioners Act 2008 (WA) in relation to his conduct between early 2008 and 17 October. In addition, it was found that he behaved in a way that constituted professional misconduct for the purpose of the National Law from 18 October 2010.

The Board made several submissions relating to Dr Singh’s credit generally. Including his recitation of inaccurate qualifications, lack of recall on specific matters which highlights his unprofessional approach to practice and the adoption of scientific studies when it suited him and the rejection of all others which did not. The Tribunal accepted the Board’s submissions and in light of surrounding evidence, accepted that much of Dr Singh’s evidence was deliberately untrue.

Dr Singh claimed that he had failed to take adequate notes because of his patients’ public profile. Experts testified that in respect of care of prominent people where privacy may be at risk there is the option of placing records in the hands of the patient, rather than failing to take notes all together. The Tribunal accepted that prominent or renowned people should be treated the same as others in respect of note taking and found that Dr Singh’s notes were totally inadequate.

Lessons Learnt

Dr Singh was found to be in contravention of s76 of the Medical Practitioners Act 2008 (WA) by acting carelessly, incompetently and/or improperly in a way that constituted professional misconduct. This decision highlights the importance of a clear therapeutic indication being present for the prescription of steroids and associated drugs which are commonly used for weight loss and physical conditioning. Further, the failure to take any or adequate clinical notes was a key consideration in finding Dr Singh’s general practice professionally deficient. Where a practitioner is treating a ‘prominent person’, safeguards can be put in place to protect their privacy. However, notes taken must still be adequate in detail and length. A failure to take any clinical notes will be a clear failure of the practitioner in fulfilling their professional duties.

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