Maladministration, Misconduct, Negligence or Serious Mismanagement: Who is failing how?
There is a point where repeatedly calling what happened in this case a series of “failures” becomes too vague.
The Parliamentary and Health Service Ombudsman has already formally found maladministration in NHS Buckinghamshire, Oxfordshire and Berkshire West ICB’s handling of female sterilisation policy and my complaint.
Since then, I have documented further problems involving the replacement policy, equality, leadership accountability, Freedom of Information compliance, internal review, complaint handling, transparency and repeated attempts to close correspondence without resolving the questions I was asking.
Some of these events clearly fit the language of maladministration. Some raise questions of mismanagement, misconduct, statutory non-compliance, equality failure and fitness for senior NHS office.
There is also another issue that cannot be separated from any of this:
harm.
A healthcare policy is not just paperwork. If a policy makes one form of contraception harder to access, steers women toward another form they did not want, exposes them to additional treatment and its risks, delays permanent contraception, and does so unequally compared with men, then the consequences can be physical, psychological, autonomy-related and equality-related.
That does not automatically mean every event described on this site amounts to legal negligence. Negligence has its own legal test. But the possibility of foreseeable harm should have been central to the policy-making process long before any woman needed to bring a legal claim.
Where I apply labels such as misconduct or serious mismanagement to individual behaviour, I am giving my interpretation of the evidence. I am not claiming that a court, regulator or disciplinary body has already made those findings.
You can follow the complete chronology on The Timeline and examine the underlying correspondence and records in my Evidence Folder.
I did not spend years of my life investigating this so that everybody involved could eventually move on, collect another senior title and continue exercising power while what happened disappears into institutional memory.
That is one of the main reasons this website exists.
I started as one woman asking for permanent contraception.
What followed became an investigation into how NHS policy is made, what evidence gets considered, how women’s decisions about their own bodies are treated, how unequal healthcare pathways are justified, what happens when senior executives give assurances that later collapse under independent scrutiny, and what happens when you ask the most uncomfortable question of all:
If you look at The Timeline, you can now see the whole pattern in one place.
- A restrictive policy.
- A complaint.
- Assurances from the Chief Executive.
- An Ombudsman investigation.
- Formal findings of maladministration.
- A replacement policy that again restricts women’s choices.
- No leadership review.
- A Freedom of Information request asking for the evidence.
- A statutory deadline missed.
- An Internal Review admitting the failure.
- No meaningful internal investigation into who was accountable.
- Another complaints route closed.
- A second transparency battle over male vasectomy commissioning.
- And repeated external escalation because the organisation would not meaningfully scrutinise itself.
At some point, “things went wrong” is no longer enough.
What does maladministration actually mean?
Maladministration is primarily an administrative-accountability concept rather than a criminal offence.
It describes public administration that falls below the standards expected of a public body.
That can include:
- failing to follow proper procedures;
- failing to consider relevant evidence;
- failing to properly explain a decision;
- poor or incomplete record-keeping;
- unreasonable delay;
- inconsistent treatment;
- failure to act fairly or proportionately;
- failure to correct mistakes;
- and failure to learn from complaints.
The Parliamentary and Health Service Ombudsman’s own principles expect public bodies to make decisions properly, keep adequate records, explain themselves, act fairly and put mistakes right.
Its remedy principles also recognise that maladministration can result in injustice or hardship, and that where this happens a public body should consider remedies not only for the complainant but, where appropriate, for other people affected by the same failure.
In this case, maladministration is not simply my description.
The Ombudsman independently found it.
You can read more in What the Ombudsman Found — and What It Could Not Do.
What is the difference between maladministration and misconduct?
This distinction is important.
Maladministration describes what went wrong in administration.
Misconduct describes the behaviour of a person.
An organisation can administer something badly without proving that one particular employee committed misconduct.
But individual conduct becomes relevant when somebody fails to meet the standards reasonably expected of their role.
For senior NHS leaders, the Fit and Proper Person Test framework is especially important because NHS England explicitly identifies behaviours that may be relevant to serious misconduct or serious mismanagement.
Those include:
- dishonest conduct;
- discrimination;
- disregard for appropriate standards of governance;
- resistance to accountability and undermining due process;
- failure to report significant issues;
- repeated or ongoing tolerance of poor practice;
- and continued failures in managing important business, financial or clinical functions.
NHS England also says context matters: whether behaviour was deliberate or reckless, whether dishonesty was involved, whether problems were repeated or continued over time, what role the person played and what impact the conduct had on public confidence.
That framework becomes very relevant when we stop looking at each event in isolation.
What does serious mismanagement mean?
Mismanagement is not necessarily one spectacular act.
It can be repeated failure to properly manage systems, risk, people, compliance and organisational responsibility.
At Board level, that matters because senior leaders are not only responsible for what they personally type into an email.
They are responsible for creating and maintaining systems that work.
If statutory processes repeatedly fail, if governance safeguards fail, if bad policies survive, if complaints do not create learning, if accountability disappears between departments and if leadership is notified without meaningful correction, then the question becomes bigger than one administrative error.
It becomes:
What does negligence mean?
Negligence is different again.
A legal negligence claim ordinarily requires a chain something like:
- a duty of care;
- a breach of that duty;
- causation;
- and identifiable harm or damage.
So not every bad policy is automatically negligent.
Not every example of maladministration creates a successful negligence claim.
Not every failure of governance causes a legally recoverable injury.
But that does not mean the harm caused by policy is irrelevant.
Quite the opposite.
The real question is whether the NHS created or maintained a healthcare pathway capable of causing foreseeable harm, and whether that foreseeable harm was properly considered.
Can a commissioning policy actually harm a patient?
Of course it can.
A healthcare policy determines what happens to real people and real bodies.
If a woman asks for permanent contraception and the NHS makes that treatment unavailable, exceptional, delayed or conditional on trying another contraceptive first, the policy changes the healthcare she receives.
The chain can look like this:
That is not theoretical.
The NHS itself recognises that hormonal contraception can involve side effects and risks.
Commonly reported effects include headaches, nausea, mood changes, changes to bleeding, sore breasts, acne and weight changes, although the NHS also notes that evidence does not establish that every reported symptom is necessarily caused by hormonal contraception.
Some hormonal methods also carry small increased risks such as blood clots and breast cancer.
That does not make hormonal contraception “bad”.
For millions of women it is an excellent choice.
The issue is whether it is their choice.
A treatment somebody freely chooses after weighing its advantages and disadvantages is not ethically equivalent to a treatment somebody is pressured or channelled toward because the healthcare system has restricted the option they actually want.
Why does NICE make this harm argument stronger?
NICE’s contraception quality standard says women asking for contraception should receive information about, and be offered a choice of, all contraceptive methods.
That explicitly includes permanent methods.
Female sterilisation is one of them.
NICE says healthcare practitioners should help women choose the method that suits them best, and commissioners should ensure services work together so women can receive their preferred method.
So when an ICB creates a policy that effectively says:
You may want permanent contraception, but before we respect that choice you need to try or prove the unsuitability of another method,
there is an obvious question about whether the local policy is facilitating contraceptive choice or overriding it.
This matters even more because the documents I eventually obtained showed that clinicians themselves had raised concerns about LARC being treated as a condition rather than an option, and supporting material referred to patient choice as something that should be paramount.
Does the Supreme Court Case Montgomery v Lanarkshire Health Board make bodily autonomy part of the negligence question?
Yes.
The Supreme Court decision in Montgomery v Lanarkshire Health Board is foundational because it rejected the older paternalistic idea that doctors get to decide what information or choices a competent adult needs.
The Court made clear that an adult of sound mind is entitled to decide which available treatment, if any, to undergo.
A doctor must take reasonable care to make sure the patient knows about material risks of the recommended treatment and reasonable alternatives.
The whole point is meaningful participation in decisions about your own body.
That creates an important question in this case:
Montgomery applies most directly to the clinical encounter between professional and patient.
My case sits partly upstream of that encounter, because the commissioning policy itself can determine what the clinician is allowed to offer.
That does not automatically make the policy unlawful under Montgomery.
But it does make the conflict with informed choice and bodily autonomy impossible to ignore.
Is loss of bodily autonomy itself a form of harm?
Yes, in my view it plainly is.
The law does not only care about whether somebody developed a measurable physical injury.
Bodily integrity, private life and reproductive autonomy are themselves serious legal and ethical interests.
Healthcare decisions involve what happens to somebody’s body.
Being denied meaningful control over those decisions can therefore be harmful even before we ask whether there was a blood clot, depressive episode, painful side effect or unintended pregnancy.
The relevant harms can include:
- physical side effects from an unwanted alternative treatment;
- psychological distress;
- loss of reproductive autonomy;
- repeated invasive appointments or procedures;
- delay in receiving preferred care;
- prolonged fear of unintended pregnancy;
- and the humiliation or distress of repeatedly having a competent adult decision questioned.
That is why I reject the idea that this case is simply about “funding criteria”.
Can unequal access create unequal health outcomes?
Absolutely.
The NHS Constitution recognises a right not to be unlawfully discriminated against and gives patients rights around informed choice and involvement in decisions.
ICBs also operate under statutory responsibilities relating to reducing inequalities in access to healthcare and in outcomes.
That means equality cannot be reduced to:
“Men and women both technically have some kind of sterilisation pathway.”
The actual pathway matters.
If men may receive:
- NHS-funded vasectomy;
- private-provider access;
- direct referral;
- or self-referral;
while women face:
- GP referral;
- specialist assessment;
- discussion of alternatives;
- LARC gatekeeping;
- approval criteria;
- and potentially much longer surgical waiting pathways;
then the difference creates a different health burden.
Women may spend longer using contraception they did not want.
They may experience additional side effects.
They may need more appointments.
They may remain at risk of unintended pregnancy for longer.
They may simply abandon their request because the pathway becomes exhausting.
Unequal access can therefore create unequal health burdens.
This is why my investigation into male vasectomy commissioning matters so much. You can read that story in The Gender Gap in Healthcare: The Vasectomy Pathway NHS Thames Valley Would Not Explain.
What evidence did the ICB show that it had considered these harms?
This is exactly what I have been trying to establish.
My Freedom of Information request asked for evidence around:
- the final approval process;
- equality analysis;
- clinical evidence;
- legal and ethical reasoning;
- comparison with male vasectomy;
- bodily autonomy;
- informed choice;
- and whether the post-Ombudsman reforms had actually been followed.
The disclosure I eventually received answered some things, but it also exposed major gaps.
The ICB expressly acknowledged that the detailed comparison I had requested between female sterilisation and the male vasectomy pathway had not been conducted in the earlier supporting work.
The equality assessment disclosed to me was pre-Ombudsman, recorded no specific patient engagement, and there was still a question over whether later equality work described in the approval papers had ever been completed and disclosed.
The ICB’s own material also referred to later post-Ombudsman work — including a refreshed report, a 14-item action tracker and further comments raising “significant concerns” — yet those were among the records I was still chasing.
So one of my central concerns remains:
Does all of this automatically prove legal negligence?
No.
And that distinction matters.
A successful negligence claim normally needs a particular claimant to show a duty of care, breach, causation and damage.
For example, a woman who was inadequately informed about her options, was directed into a treatment she would otherwise have refused, and suffered injury because of it might raise a much more conventional negligence issue.
At commissioning level, the legal routes can be different.
They may include:
- public law and judicial review;
- the Equality Act and Public Sector Equality Duty;
- statutory NHS duties around healthcare inequalities;
- Article 8 and bodily autonomy;
- informed-consent law;
- the NHS Constitution;
- and maladministration resulting in injustice or hardship.
So I would not claim that every failure documented here is clinical negligence.
I would say something more precise:
Whether a particular woman could establish legal negligence would depend on what happened to her personally.
But the possibility of harm should have been part of the policy-making process before any woman ever needed to sue.
Does the failure to learn after the Ombudsman make later harm more serious?
In my view, absolutely.
The first time an organisation gets something wrong, it may say it failed to understand the problem.
That argument becomes much weaker after an independent Ombudsman has already identified the underlying failures.
The Ombudsman’s remedy principles expressly say public bodies should learn from complaints, change policies and systems where necessary and avoid repeating maladministration.
That makes the February 2026 replacement policy especially important.
The ICB had already been told that its earlier work around female sterilisation involved serious failures.
Yet the new policy still contained a requirement that women undergo, or demonstrate the unsuitability of, a LARC trial before sterilisation.
I challenged that restriction directly in my correspondence with the Chair of the ICB - Dr Priya Singh.
Within months, the LARC requirement itself was being reconsidered.
So the question becomes:
For me, that makes the later events more serious than the original mistake.
What does Dr Nick Broughton’s role raise?
Dr Nick Broughton, Chief Executive and Accountable Officer of NHS Thames Valley ICB, sits at several major points in this history.
He issued the final Chief Executive response to my original complaint.
That response gave me false reassurance about how robustly the policy had been developed and reviewed. The Ombudsman subsequently found important shortcomings in the evidence, reasoning, equality comparison, consultation and complaint handling.
You can examine those contradictions in The Gaps Between Dr Nick Broughton’s Claims and the Ombudsman Findings.
After the Ombudsman report, I asked whether those findings had triggered any consideration of his Fit and Proper Person status.
They had not.
Chair Dr Priya Singh confirmed in writing that:
- the Board, its committees and associated groups had not considered leadership accountability following the PHSO findings;
- and Dr Broughton’s FPPT status had not been reviewed, reassessed or discussed because of them.
That is documented in her response.
Then came the FOI failure.
As Chief Executive and Accountable Officer, Dr Broughton sat at the top of an organisation that missed a statutory information deadline. What's worse is that the Information Officer at the ICB invented a new deadline, giving themselves TWO MONTHS beyond the statutory deadline, and declined and avoided to give me Legal reasons and justifications for it.
I directly copied the CEO and Accountable Officer Nick Broughton into later correspondence challenging the continuing breach.
I saw no visible intervention from him that resulted in immediate compliance.
To me, that raises questions about:
- leadership competence;
- oversight;
- tolerance of poor practice;
- governance;
- and fitness for senior office.
Those categories matter because NHS England’s FPPT framework itself treats disregard for governance, resistance to accountability and repeated tolerance of poor practice as potentially relevant to serious misconduct or serious mismanagement.
Why does Dr Nick Broughton’s national role make these questions even more important?
Dr Broughton is not only Chief Executive and Accountable Officer of NHS Thames Valley ICB.
In 2026 he was also appointed in ans so holds the NHS England role of National Priority Programme Director for Mental Health, Learning Disability and Neurodevelopmental Conditions.
That role involves national leadership affecting people with severe mental illness, learning disabilities and neurodevelopmental conditions.
Many of those patients may face far greater barriers than I do when challenging authority, understanding complaints systems, navigating policy and making institutions answer difficult questions.
I find that deeply relevant.
I am persistent.
I understand research.
I keep records.
I challenge language.
I use FOI law.
I escalate.
I publish.
A vulnerable patient with a learning disability may not be able to do any of those things.
I will examine Dr Broughton’s career, progression and current national responsibilities separately.
What does Dr Priya Singh’s conduct raise?
Dr Priya Singh, Chair of NHS Thames Valley ICB, has a central governance role.
I approached her because the Ombudsman findings raised obvious questions about the assurances previously given by her Chief Executive.
Her response established that there had been no leadership-accountability consideration and no FPPT review connected to those findings.
I then separately challenged her over the February 2026 female sterilisation policy.
I asked whether it complied with equality law, informed consent, bodily autonomy, clinical guidance and the Ombudsman findings.
Instead of a straightforward answer, the correspondence stretched across repeated chasers and explanations while the policy itself was being reconsidered.
Eventually, correspondence was closed - by her - without answering my questions and challenges about the new policy and the gender gap inequality of permanent contraception and just giving me empty promises of updates - that never materialised to this day (16 September 2026)
You can read that history in Why NHS Chair Dr Priya Singh Couldn’t Defend the February 2026 Female Sterilisation Policy.
To me, the questions are about:
- adequacy of Chair oversight;
- FPPT governance;
- willingness to scrutinise the Chief Executive;
- openness;
- and resistance to accountability.
I am not saying a disciplinary body has found Dr Singh guilty of serious misconduct.
I am saying I believe the evidence warrants scrutiny of whether she fulfilled the accountability responsibilities of her role.
What does Mark Gittins’s Internal Review tell us?
Mark Gittins, Information Governance Consultant, conducted the Internal Review of FOI-TV-2606-105.
His review accepted that my request had not been handled within the statutory timeframe.
That was important.
But I challenged the review because I believed it did not properly establish:
- where the ICB’s own escalation controls failed;
- who was responsible at each stage;
- what executive oversight occurred;
- how disputed redactions had appeared;
- and what governance consequences followed from the admitted breach.
When I kept challenging those questions, Mr Gittins eventually said the ICB would provide no further response on the Internal Review.
That does not automatically prove misconduct by him.
But it does raise a serious question about whether an internal review mechanism that can acknowledge a statutory failure without meaningfully establishing accountability is functioning as an accountability mechanism at all.
To me, Mark Gittins’s role raises more than a question about whether the Internal Review was technically adequate.
He was the person tasked with reviewing an admitted statutory failure. His own review accepted that NHS Thames Valley ICB had missed the legal FOI deadline, yet when I asked the obvious follow-up questions — where did the controls fail, who was responsible, why had the ICB’s own escalation safeguards not worked, what happened with the disputed redactions, and what accountability followed — those questions were never properly resolved.
That starts to look, in my opinion, like poor governance and potentially mismanagement of the review process itself. An Internal Review should not simply acknowledge that something went wrong; it should help establish how it went wrong, whether the organisation’s safeguards worked, what needs correcting and who is responsible for making sure it does not happen again.
What concerns me even more is that, after I continued pressing those unresolved questions, Mr Gittins told me that the ICB would not provide further responses on the Internal Review. To me, that can reasonably be viewed as resistance to accountability: the review admitted the breach but then stopped engaging when scrutiny moved from “was the deadline missed?” to “who is accountable for allowing this to happen?”
I am not saying that this proves serious misconduct by Mark Gittins. But I do think it raises legitimate questions about professional judgement, adequacy of internal governance, willingness to investigate organisational failure, and whether the Internal Review function was being used to identify and correct problems or simply to administratively close them.
What does Hannah Iqbal’s position raise?
Hannah Iqbal, Chief Strategy and Commissioning Officer, appears in this story because of her senior organisational role and because she was included in later escalation around commissioning and FOI failures.
I have not seen evidence proving that she personally caused the original statutory breach. I would therefore not label her conduct misconduct on the evidence I currently have.
The question is more basic:
That remains an accountability question I think deserves an answer, because through this whole process and that many failures - she's been totally incognito and never showed up even once in correspondence. So that begs the questions: what is she paid to do, and what is she responsible for and failing at?
Hannah Iqbal’s position raises a different kind of question because I do not currently have evidence showing that she personally caused the original FOI failure.
But she is Chief Strategy and Commissioning Officer, a very senior executive role, and she was directly included in later correspondence about commissioning, transparency and the continuing failures. At that point the issue was no longer simply that one FOI had been delayed. The organisation had already admitted statutory non-compliance, serious questions had been raised about internal controls, and I was also challenging how current commissioning decisions — including vasectomy provision and equality between male and female permanent contraception — were being governed.
For me, the accountability question is therefore not only, “Did Hannah Iqbal cause the problem?” It is also: once a senior executive responsible for strategy and commissioning becomes aware of an admitted legal failure and serious concerns about the transparency and equality of commissioning decisions, what duty does she have to intervene, investigate or ensure that somebody does?
If a senior executive is notified of significant governance concerns within her area of responsibility and no meaningful corrective action follows, that can, in my view, raise questions of management failure, inadequate oversight and tolerance of poor practice. Those are exactly the kinds of issues that become relevant when assessing whether senior leadership systems are functioning properly.
I am not claiming that the current evidence establishes serious misconduct by Hannah Iqbal. It does not. But I do think her apparent lack of visible intervention deserves scrutiny.
Senior leadership accountability includes what people fail to do after they know that something has gone wrong.
What does Lorri Josey’s refusal to investigate add?
Lorri Josey, Complaints Manager in the Public & Patient Experience Team, became involved after the FOI Internal Review.
I asked PPET to investigate something distinct from my information-law rights.
I asked them to investigate:
- staff conduct;
- failed internal controls;
- management response;
- executive oversight;
- and governance accountability for the admitted FOI failure.
Ms Josey repeatedly directed me toward the Information Commissioner’s Office instead. Her correspondence identifies her role as Complaints Manager in PPET.
I repeatedly explained that the ICO can investigate information-law compliance but is not NHS Thames Valley ICB’s HR department, disciplinary process, management function or executive-governance mechanism.
No alternative internal investigator was identified.
Lorri Josey’s role raises a more direct accountability question because she was not simply a senior manager copied into correspondence. She was the Complaints Manager in NHS Thames Valley ICB’s Public & Patient Experience Team, and I specifically asked her team to investigate the organisational conduct and governance failures that had emerged from the admitted FOI breach.
I repeatedly explained that I was not asking PPET to conduct another Freedom of Information Internal Review. That process had already happened. I was asking who within NHS Thames Valley ICB would investigate the things the ICO could not investigate for the organisation: failed internal controls, staff conduct, management response, senior leadership intervention, accountability and whether remedial, governance or disciplinary action was required.
Initially, I was told that these matters could be dealt with through the FOI Internal Review. Once that review had concluded without resolving them, I returned to PPET and asked again for a corporate complaint to be opened.
Lorri Josey then maintained that the appropriate route was the Information Commissioner’s Office.
Eventually, PPET relied on Regulation 8(1)(g) of the Local Authority Social Services and National Health Service Complaints (England) Regulations 2009, which excludes certain complaints concerning matters subject to Freedom of Information legislation from the NHS complaints procedure.
But that did not answer the question I was actually asking.
I specifically asked PPET to address Regulation 8(3) and explain what happened to the separate concerns about staff conduct, failed governance, management response and executive accountability. I also asked that, if PPET itself was not sufficiently independent or did not have jurisdiction, the concerns be escalated to another appropriate route — for example a senior independent director, Freedom to Speak Up function, NHS England regional governance route or another body capable of examining the conduct and governance issues.
I was not given a substantive explanation of why those separate issues could not be investigated internally. Nor was I given a policy or legal analysis explaining why no alternative internal or external governance route should be engaged. Instead, the matter was ultimately declared closed.
That is significant to me because a complaints function is not only there to tell people which matters it will not investigate. Part of effective complaint handling is identifying the substance of a concern, making sure it reaches the correct part of the organisation and ensuring serious issues are not simply lost because they cross departmental boundaries.
If a Complaints Manager is directly presented with allegations of failed internal controls, staff conduct concerns, admitted statutory non-compliance and possible senior leadership failures, and the response is effectively to redirect the complainant elsewhere without ensuring that anybody inside the organisation examines those matters, I think that can reasonably raise questions about poor complaint management, inadequate escalation, failure of organisational learning and potentially mismanagement of the complaints function itself.
It also raises a question about resistance to accountability. I had made the distinction between the FOIA dispute and the wider governance complaint repeatedly. The issue was not merely whether information should have been disclosed. The issue was what the organisation was going to do about the people, systems and leadership that had allowed the admitted failure to occur and continue.
I am not claiming that Lorri Josey has been formally found guilty of misconduct. She has not. But I do think her handling of my complaint warrants scrutiny because her role placed her at the point where the organisation had an opportunity to investigate itself, escalate the concerns to somebody who could, or identify a credible alternative accountability mechanism. None of those things appears to have happened.
In my view, closing the complaint without answering where those governance and conduct concerns would actually be investigated did not resolve the accountability problem. It became part of it.
Once again - let's remember: at senior level, accountability is not limited to personally causing a failure. It also includes what leaders do — or fail to do — once significant failures are brought directly to their attention.
The matter was eventually closed.
If PPET could not investigate it, my question was simple: who could?
I asked for that route. I suggested possible escalation routes. I asked for the legal or policy basis for refusing to investigate or escalate the governance issues.
I never received an answer.
You can read the full story in The Accountability Vacuum Inside NHS Thames Valley ICB.
To me, that is evidence of a structural accountability problem.
What does the vasectomy FOI add to the equality and harm picture?
The male vasectomy investigation matters because it shows what easier access can look like.
I found NHS-funded vasectomy being delivered through private services, with self-referral available in some areas and expansion being discussed.
I then asked the ICB:
- who was commissioned;
- what referral routes existed;
- what safeguards applied;
- what equality assessments had been completed;
- and whether anyone had compared those pathways with women’s access to sterilisation.
The request was refused under Section 12 on cost grounds.
I then substantially narrowed it and asked the ICB to fulfil its Section 16 duty to provide advice and assistance.
I reduced the request to current providers, current access pathways, current equality documentation and the latest comparison with female sterilisation. :contentReference[oaicite:10]{index=10}
The wider question remains:
If the NHS can make permanent contraception convenient, privately delivered and increasingly directly accessible for men, what evidence justifies imposing substantially greater friction on women?
When does repeated maladministration begin to look like systemic mismanagement?
This is perhaps the most important question in the whole article.
One mistake is a mistake.
One missed deadline can be a mistake.
One bad complaint can be a bad complaint.
But NHS England itself says seriousness can be assessed by considering whether issues are frequent or continue over a long period.
Now look at The Timeline.
- A female sterilisation policy was created using a process later found to be maladministrative.
- My complaint about it was itself handled badly.
- The Chief Executive gave assurances I believe were contradicted by the independent findings.
- No leadership-accountability or FPPT review followed those findings.
- A replacement policy introduced another major restriction on women’s choice.
- The Chair repeatedly avoided giving me the direct compliance answer I asked for.
- The ICB then missed a statutory FOI deadline by almost two months.
- Its own Internal Review admitted that failure.
- The wider governance questions were not resolved.
- Senior leadership was directly notified.
- The complaints function would not investigate the organisational consequences.
- The disclosure itself still appeared incomplete.
- A second FOI battle then developed around male vasectomy commissioning and equality.
I think it is entirely reasonable to ask whether this crossed the line from individual instances of maladministration into systemic mismanagement.
Does lack of intention excuse the harm?
No.
This is one of the most dangerous ideas in institutional accountability.
Harm does not require somebody to sit in a boardroom and decide to hurt women.
People can be harmed because:
- bad assumptions go unchallenged;
- evidence is not properly weighed;
- equality is treated as a formality;
- nobody considers the burden of alternative treatments;
- nobody compares unequal pathways;
- poor decisions are not reviewed;
- leaders are not held accountable;
- complaints become something to close rather than learn from;
- and vulnerable people eventually stop fighting.
That is exactly why governance exists.
Why does this matter to women who will never read this website?
Because most women will never spend years doing what I have done.
Most people will assume that if an NHS policy exists, somebody has properly checked it.
Most will trust the first rejection.
Most will not file an FOI.
Most will not know what a Public Sector Equality Duty is.
Most will not challenge an Internal Review.
Most will not email the Chair.
Most will not understand an FPPT framework.
That is why the people who hold public power carry such enormous responsibility.
Why is this connected to the wider NHS crisis?
An NHS can have excellent doctors and nurses and still fail patients through poor governance.
You can put more money into healthcare and still waste it through badly designed policy.
You can publish values about openness and patient-centred care while operating systems where senior accountability is almost impossible to trigger.
When governance fails:
- poor policies survive longer;
- health inequalities survive longer;
- patients experience unnecessary treatment burden;
- warnings are missed;
- money is wasted;
- staff learn that procedures can be ignored;
- and harm can continue because nobody stops the system long enough to examine what it is doing.
That is why governance is not administrative trivia.
In healthcare, governance affects bodies, health and lives.
Does the evidence warrant investigation for serious misconduct or serious mismanagement?
I cannot make the formal finding.
A regulator, employer or authorised governance body has to investigate the individual roles, obtain explanations and reach conclusions.
But I can ask whether the threshold for investigating has been reached.
The NHS’s own framework tells organisations to consider disregard for governance, resistance to accountability, dishonest conduct, repeated tolerance of poor practice and persistent management failures.
Those terms sit far too close to what I have spent years documenting for the answer to simply be:
No review is necessary.
Who appears to carry what accountability?
| Person / function | What the evidence shows | Questions raised |
|---|---|---|
|
Dr Nick Broughton Chief Executive / Accountable Officer |
Issued the final complaint response; later independent findings contradicted important assurances; no FPPT review followed; subsequently notified of further FOI and governance failures. | Honesty, competence, oversight, serious mismanagement, tolerance of poor practice, accountability and continued suitability for senior leadership. |
|
Dr Priya Singh Chair |
Confirmed that no leadership-accountability consideration or FPPT review followed the Ombudsman findings; later closed substantive policy correspondence. | Adequacy of Chair oversight, FPPT governance, scrutiny of the CEO, openness and accountability. |
|
Mark Gittins Information Governance Consultant |
Internal Review admitted the statutory-timing failure; wider accountability questions remained disputed; correspondence on those questions was later declared concluded. | Adequacy of internal review, investigation of failed controls, redactions and organisational accountability. |
|
Hannah Iqbal Chief Strategy and Commissioning Officer |
Senior executive included in later escalation concerning commissioning and transparency. Current evidence does not establish personal responsibility for the original FOI breach. | What action was taken once senior leadership was notified? Were commissioning and governance failures internally examined? |
|
Lorri Josey PPET Complaints Manager |
Declined a separate corporate investigation into governance and conduct issues, redirected the matter toward the ICO and ultimately closed the route without identifying another internal investigator. | Whether the complaints system provided any meaningful mechanism for investigating organisational conduct and accountability. |
| NHS Thames Valley ICB | Independent maladministration findings; subsequent policy controversy; admitted FOI non-compliance; continuing disclosure, equality and accountability disputes. | Systemic maladministration, foreseeable harm, governance culture, transparency and organisational mismanagement. |
What am I not claiming?
For clarity:
- I am not saying a court has found Dr Nick Broughton dishonest.
- I am not saying a disciplinary panel has found Dr Priya Singh guilty of misconduct.
- I am not saying Mark Gittins, Hannah Iqbal or Lorri Josey have been formally found guilty of professional misconduct.
- I am not claiming that every woman affected by the policy automatically has a negligence claim.
- I am not claiming that every contraceptive alternative is harmful.
What I am saying is that:
- maladministration has already been independently established;
- foreseeable patient harm should have been part of policy design;
- the evidence disclosed to me does not show that all relevant harms and inequalities were properly weighed;
- further admitted governance failures occurred afterwards;
- and the accumulated pattern now raises serious questions that fit the NHS’s own language around governance, serious mismanagement and misconduct.
What should happen now?
I think external oversight bodies need to stop looking at these events one at a time.
The female sterilisation policy sits in one file.
The Ombudsman report sits in another.
The FPPT question sits somewhere else.
The FOI breach goes to the ICO.
The governance complaint gets redirected.
The vasectomy inequality becomes another commissioning issue.
Each issue can then be treated as small enough to explain away.
The pattern is the evidence.
That is why I created The Timeline.
I believe NHS England, the relevant regional leadership, local health scrutiny and any body responsible for appointing or overseeing senior NHS leaders should examine this history together.
Why I am not going away
I have already lost years to this.
I cannot get those years back.
But I can make sure the evidence does not disappear.
I can make sure decisions stay attached to the people and offices responsible for them.
I can make sure that when somebody is promoted or given a national role, unresolved questions about their previous leadership remain visible.
I can make it harder for the next woman to be told:
“That is simply NHS policy.”
As though policy appeared from nowhere.
And eventually, accountability has to reach people too.
Read the full evidence trail
- The Timeline — follow the complete case chronologically
- Evidence Folder — correspondence, FOIs, reports and documentary evidence
- What the Ombudsman Found — and What It Could Not Do
- Dr Nick Broughton’s Claims vs the Ombudsman Findings
- I Challenged the Policy — the CEO Told Me the Governance Was Robust
- When Maladministration Brings No Accountability
- Why Dr Priya Singh Couldn’t Defend the February 2026 Policy
- The Accountability Vacuum Inside NHS Thames Valley ICB
- The Vasectomy Pathway NHS Thames Valley Would Not Explain
- Why I Asked Oxfordshire Health Scrutiny to Investigate
Authoritative sources and frameworks
- NICE — Contraceptive information and methods — women should be informed about and offered a choice of all contraceptive methods, including permanent contraception.
- NHS — Side effects and risks of hormonal contraception — explains recognised side effects and risks relevant to the burden of alternative contraception.
- UK Supreme Court — Montgomery v Lanarkshire Health Board — informed consent, material risks, reasonable alternatives and bodily integrity.
- The NHS Constitution for England — patient choice, involvement, equality and rights within NHS healthcare.
- NHS England — Fit and Proper Person Test Framework for Board Members — serious misconduct, serious mismanagement, governance, accountability and repeated tolerance of poor practice.
- Parliamentary and Health Service Ombudsman — Principles for Remedy — correcting maladministration, remedying injustice or hardship, learning and preventing repetition.
The Ombudsman has already established maladministration.
The evidence since then shows further admitted statutory failure, continuing governance problems, unresolved questions around equality and autonomy, and repeated resistance to establishing individual accountability.
The harm question also matters. A policy that restricts one form of healthcare can change which treatment people receive, how long they wait, what risks they are exposed to and how much control they retain over their own bodies.
I believe the accumulated evidence now warrants a proper independent investigation into whether serious mismanagement or misconduct occurred, who was responsible for it, who contributed to it, who tolerated it, whether foreseeable harm was properly considered, and whether the senior leaders involved remain suitable to exercise the public power they currently hold.
That is my interpretation. Read the evidence, follow the timeline, and make your own.
