Full Hearing - Subsequent Registration Application Hearing - Emmanuel Brown

Teacher

Emmanuel Brown

Date

Dates

1 September 2026

Registration number

079072

Registration category

Secondary Mathematics

Panel

Andrew Fairie, Gemma Durnan, Robyn Wisbey (Convener)

Legal assessor

Victoria Ulph

Servicing officer

Keith Ward

Presenting officer

Catriona Watt (Anderson Strathern)

Teacher's representative(s)

Wilberforce Ehimika (JDS Solicitors)

Any reference in this decision to:

‘GTC Scotland’ means the General Teaching Council for Scotland;
the ‘Panel’ means the Fitness to Teach Panel considering the case;
the ‘Rules’ (and any related expression) means the GTC Scotland Fitness to Teach Rules 2017 or refers to a provision (or provisions) within them;
the ‘Register’ means the GTC Scotland register of teachers;
the ‘SPR’ means the GTC Scotland Standard for Provisional Registration; and
the ‘SFR’ means the GTC Scotland Standard for Full Registration.

Background

A GTC Scotland Disciplinary Sub-Committee directed on 10 March 2009 that the Applicant be removed from the Register and prohibited from reapplying for registration a period of 12 months.

In accordance with Rule 4.1, the Panel was convened to consider the Applicant’s Subsequent Registration Application, dated 15 January 2025, following his earlier removal from the Register, as described above. Rule 4.1 of the Rules provides:

A subsequent registration application is an application from a person who was removed from (or refused entry to) the Register in terms of these Rules (or the historic equivalent) or article 19 of the Order (entitled “Barred individuals”). Where an individual submits such an application (in such form as GTC Scotland reasonably requires), the application must be considered by a Panel at a hearing. The Applicant may only be admitted to the Register if a Panel is satisfied that he/she is now fit to teach.

Evidence and Submissions

The Panel heard oral evidence from the Applicant and from the Presenting Officer. In addition, the Panel admitted all of the documents listed below as evidence for the purposes of the hearing:

SRA Application Papers

SRA Application Form and supporting documentation lodged by Applicant, including:

Abbey Manor College Time Sheet (02.07.07)
Abbey Manor College Time Sheet (18.06.07)
Abbey Manor College Time Sheet (21.05.07)
Abbey Manor College Time Sheet (30.04.07)
Applicants Proof of Address 1
Applicants Proof of Address 2
Agency Email to Resume at [redacted]
Bertson Education Timesheets (21.01.08 – 04.02.08)
Applicant Birth Certificate
CPD Screenshot (Unknown)
Words First - Certificate
Cumberland School Timesheet (14.12.07)
Cumberland School Timesheet (15.02.08)
Cumberland School Timesheet (17.12.07)
GTC Scotland Email to Applicant
GTC Scotland Certificate (Maths and Numeracy)
GTC Scotland Certificate (Maths)
Heathcote School Timesheet (18.03.08)
KICC Engagement Letter
Letter dated 18 December 2007 to GTC Scotland
Applicant Passport
Prendergast School Time Sheet (21.03.08)
PVG Result for Applicant, dated January 2025
Applicant Submission – Regarding Fitness to Teach
Reference for Applicant – [redacted]
Reference for Applicant – [redacted]
St Martins School Timesheet (28.04.08)
Applicant Statement – Regarding SRA
Applicant Teaching Record (December 2007)

Servicing Officer’s Papers

Notice of Full Hearing, dated 2 June 2026, with cover email and delivery receipt
Remote Hearing Decision, dated 17 November 2025
Joint Minute of Agreement, Agreement of [redacted] Witness Statement, dated 11/12 June 2026

Presenting Officer’s Papers

Presenting Officer’s Submissions (Updated), dated 10 September 2025 and 9 October 2025
Presenting Officers Submissions, Appendix (Updated) to Submissions, dated 10 September 2025, including:
- Fitness to Teach Decision, dated 11 March 2009
- Hearing Papers, dated 2009
- Archive Papers, including hearing transcript, dated 10 March 2009
- Letter from Emmanuel Brown to GTC Scotland, dated 18 December 2007
- GTC Scotland Response to request for information regarding Emmanuel Brown, dated 8 November 2024
- TLTP Registration Form, dated 6 November 2023
- Email from [redacted]to[redacted], dated 21 July 2025, enclosing updates and changes to the checks which were made on Employer Access
- Email from Department of Education to[redacted], dated 5 August 2025
- GTC Scotland Statement of[redacted], dated 10 December 2025
- Placements by TLTP for Emmanuel Brown, 2023-2024
- CV of Emmanuel Brown provided to TLTP, dated 2023

Teacher’s Papers

Provisional Registration Document, dated 2007
Agency email to [redacted]to resume at Alec Hunter School, dated 2007
Evidence of 3 weeks of work at Alec Hunter School, dated 2008
Schools and Settings [redacted] worked at previously, undated
Applicant’s Letter, to [redacted], dated 21 June 2008
GTC Scotland Letter removing [redacted]from register, dated March 2009
[redacted] DBS document, dated September 2023
[redacted] Email of November 2024
PVG Disclosure Document, undated
GTC Scotland Letter about possible barring action by TRA, dated 27 February 2025
Applicant’s Response to Presenting Officer’s Submission
Updated Presenting Officer’s Submissions, dated September 2025
Applicant’s Response to Presenting Officers updated Submission

Preliminary Submissions (2024 Conduct)

The Presenting Officer referred the Panel to Part 4 of the 2017 Rules and to the witness statement dated 9 October 2025 regarding the Applicant’s subsequent application for registration dated 15 January 2025.

The Presenting Officer submitted that, in 2009, when seeking full registration, the Applicant had completed the relevant form with false information. In terms of Rule 4.1, the Applicant could only be readmitted to the Register if the Panel was satisfied that he was currently fit to teach.

The Presenting Officer referred the Panel to pages 82–83 of the bundle, where the decision to remove the Applicant from the Register was set out. It was confirmed that, on his final report, the Applicant had forged the signature of the Assistant Headteacher and had thereby obtained registration by fraud. At pages 87–94 of that decision, it was confirmed that the Applicant had forged the signature on multiple occasions.

The Applicant had subsequently applied for registration. Prior to that application, GTC Scotland had been contacted by TLTP, an employment agency, which had become aware that the Applicant had previously been removed from the Register and had contacted GTC Scotland to ascertain the reasons for his removal.

The Presenting Officer referred the Panel to pages 177–185 of the bundle, being the TLTP registration form completed by the Applicant. It was accepted that the Applicant was not holding himself out as a registered teacher. However, in the declaration section at page 185, when asked whether he had ever been subject to disciplinary sanction by a regulator in this country or abroad, the Applicant answered “no”. The Presenting Officer submitted that the Applicant must have known that the correct answer to that question was “yes” and that he had answered the question falsely in order to obtain teaching experience.

In determining whether it could be satisfied that the Applicant was currently fit to teach, the Presenting Officer submitted that the Panel required to consider the period between the Applicant’s removal from the Register and his current application and to assess his conduct during that period.

The Presenting Officer referred to the witness statement of [redacted]at page 219 and to the CV referred to at page 229. The Applicant’s CV omitted any reference to the work he had undertaken in Scotland prior to his removal from the Register. It was submitted that this omission, taken together with the false declaration made in the application form, demonstrated that the Applicant’s actions had been deliberate.

At the relevant time, the Applicant was not registered with the Teaching Regulation Agency (TRA) and the register could not therefore be checked as he did not have a teaching regulation number (TRN). The position did not become clear until June 2024, when the register became searchable by name and date of birth, with the result that the Applicant’s removal by GTC Scotland came to the attention of the employment agency.

The witness statement of [redacted]confirmed that care required to be taken when completing the application form and that the Applicant had failed to do so. It then became apparent that he had previously been removed from the Register for the fraudulent completion of forms by forging signatures. [redacted] made clear that the employment agency required to be able to rely upon honest declarations from Applicants.

It was submitted that, had the Applicant made the correct declaration on the form, there would have been an opportunity for him to explore and explain the circumstances. Instead, he had made a false declaration for the purpose of obtaining a teaching post. He knew, and had always known, that he had been removed from the Register in Scotland and ought to have taken the relevant steps.

The Presenting Officer submitted that the onus was upon the Applicant to demonstrate his current fitness to teach. The Panel was referred to paragraphs 1.4 and 1.5 of COPAC. It was submitted that the Applicant had failed to demonstrate the necessary standards of integrity and honesty; that his conduct demonstrated a history of deficiencies in integrity and honesty; that he had shown little or no insight; and that there remained a risk of repetition.

Opening Statement for the Applicant 

On behalf of the Applicant, the Representative referred the Panel to pages 247 to 248 of the bundle and advised the Panel that they must not be fettered by the previous decision of an earlier panel. It was not argued that what the Applicant did was correct but submitted that what happened then should not condemn an Applicant and it should not be something that should forever prevent the Applicant from teaching. It was submitted that the particular application for subsequent registration should be assessed on the circumstances, including the fact that the Applicant had made a terrible error causing removal. It was explained that the Applicant had made every effort to have the Assistant Headteacher sign in person and had travelled between London and Essex every day for three weeks. On the Applicant’s behalf it was noted that that at the time of removal, the Applicant had not been legally represented, and it was submitted that a lesser penalty may have been appropriate.

Turning to the present matter, it was submitted that the Applicant had owned up and had completely missed ticking the right box. It was submitted that this is easy to do when it is a tick-box exercise. There was no intention but simply an error and lack of attention. Evidence was heard from the Applicant, who confirmed that he had learned his lesson since 2009 and had changed. He had been rushed when he answered the questions on the form, and this was not a deliberate act. He sought that he be given the benefit of doubt in this respect on the balance of probability with respect to the question of conduct, while it was clear what was expected of a teacher. It was submitted that a teacher was not expected to be infallible. He had made an honest mistake, and it was not the case that there were fixed penalties. Humans are fallible, and he made an error. He was aware of his removal by GTC Scotland at page 248 of the bundle. The Applicant had not been removed due to any safeguarding issue, but rather because of the forging of the signature. It was not an issue of competence. The Applicant acknowledged the terms of the decision and that he should have disclosed it to the employment agency. He had reflected on it over the years and had learned his lesson. He understood the standards expected of a teacher and was now more patient and willing to learn.

The Applicant stated that he was a person with good experience and understood professional boundaries. He wished to undertake a training course to become a qualified teacher and had done voluntary work preparing students for GCSEs, along with his voluntary work working for the British Heart Foundation.

Panel Questions

In response to questions from the Panel, the Applicant explained that he had first applied for registration with GTC Scotland in 2007 after seeing an advertisement online. At that time, he was living in London and did not intend to live or teach in Scotland. When asked why he had applied to GTC Scotland rather than the relevant teaching body in England, the Applicant explained that he was a trained teacher from Ghana, had an interest in teaching and understood at the time that there was a route to registration with a teaching body in Scotland which was not available to him in England. He stated that, by 2023, he understood that the position in England had changed and that it was possible to apply through a route there.

The Panel asked the Applicant about his teaching competence and whether he could provide examples or evidence demonstrating this. The Applicant stated that he had assisted a number of people with mathematics, including church members and others studying for GCSEs and A-levels. He had also undertaken voluntary teaching at school and continued to assist children known to him with mathematics. He described teaching as his passion.

When asked about his more recent teaching experience, the Applicant explained that, following difficulties with his immigration status in 2009, he had not taught in a classroom for a period. Following obtaining [redacted]in 2023, he had undertaken work as an unqualified teacher in a secondary school, assisting pupils with basic mathematics, including addition, subtraction and multiplication, as well as other basic educational work. When specifically asked whether his teaching in the United Kingdom, whether on placement or in a voluntary capacity, had ever been observed and formally assessed, the Applicant confirmed that it had not.

The Panel also questioned the Applicant about his knowledge and understanding of the Scottish education system and curriculum. He was asked about Broad General Education (BGE), the Senior Phase and the transition between them. In response, the Applicant referred to the importance of equal opportunities for children, stating that every child should have an opportunity to learn and develop in an appropriate environment.

The Applicant was asked whether he was up to date with the changes concerning the transition from the SQA to Qualifications Scotland. He indicated that he was not fully aware of the current changes, although he had some limited awareness of them. When asked about the current Curriculum Improvement Cycle within Scottish education, the Applicant confirmed that he was not aware of it.

The Panel sought further information about the teacher training programme which the Applicant wished to undertake in England. The Applicant explained that this was a one-year programme involving placement within a school alongside university based training. He understood that he would spend three days per week in the classroom and two days at university. During the school placement, he would be assigned to a class and supervised by a teacher who would observe his teaching and oversee his work throughout the year. Successful completion of the programme would enable him to obtain Qualified Teacher Status (QTS). He confirmed that he had not previously undertaken a teacher training programme in the United Kingdom and that his intended subject specialism was mathematics.

Finally, the Panel asked the Applicant to clarify the category of GTC Scotland registration he was seeking. The Applicant explained that he had previously held provisional registration and confirmed that he was seeking provisional registration again. He stated that he had made enquiries with GTC Scotland about the available route to qualification and understood that, notwithstanding that he was based in England, successful re-registration with GTC Scotland could provide a route towards obtaining the teaching qualification or status required for his intended career progression.

Closing Statement for the Applicant 

The Applicant’s Representative thanked the Panel for providing the Applicant with the opportunity to be heard. He submitted that the Applicant had not had such an opportunity previously because, at the relevant time, he had been unable to afford representation or travel to Scotland. He explained that aspects of the Applicant’s current representation had been provided on a pro bono basis.

The Representative submitted that, from his dealings with the Applicant as a client, he had found him to be an easy going and ordinarily composed individual. However, he had observed that the Applicant found the present proceedings daunting and nerve racking. During a short break in the proceedings, the Representative had spoken with the Applicant and formed the view that he was particularly anxious about appearing before the Panel. He submitted that this anxiety had been apparent at times in the Applicant’s manner when answering questions. The Representative emphasised that the Applicant did not take the proceedings lightly and was grateful for the opportunity to put his case before the Panel.

The Representative submitted that the Applicant regretted his previous actions which led to his removal and had learned from what had occurred. The Applicant had indicated that, in future, he would be more patient, consider matters more thoroughly and seek advice from others, including other teachers, whenever he was uncertain as to the appropriate course of action.

In relation to the events of 2008–2009, the Representative submitted that the Applicant had felt isolated and unsure as to what he should do. Against a background of pressure and time constraints, he had made what the Representative described as a “deplorable decision”. The Representative submitted that the Applicant had learned from that experience and now recognised the importance of taking time to consider matters and seeking advice when required.

The Representative also submitted that the regulatory process had a role not only in addressing wrongdoing but in assisting and directing teachers and aspiring teachers towards better professional practice. He expressed appreciation for the manner in which the present proceedings had been conducted, describing the process as methodical and systematic and submitting that it had afforded the Applicant a fair opportunity to be heard and to respond to questions.

The Representative asked the Panel to take account of the Applicant’s continuing passion for teaching. He submitted that the Applicant remained willing to assist others with mathematics even when he was not being paid to do so and described teaching as being almost a “calling” for him. He further referred to the Applicant’s voluntary work, including his work with the British Heart Foundation, as demonstrating a willingness to give back to society.

The Representative submitted that the Applicant’s previous conduct was not a true reflection of his character. He acknowledged that the Applicant had made errors but submitted that he had accepted responsibility for them. He further submitted that, if afforded another opportunity, the Applicant was unlikely to repeat his previous conduct. He characterised this as effectively the Applicant’s “last chance saloon” and submitted that the Applicant fully appreciated the significance of any further opportunity afforded to him.

Consideration of Evidence

The Panel gave careful consideration to all of the evidence and took account of the submissions made by the parties.

The Panel determined that this was a serious matter. The original conduct which had resulted in the Applicant’s removal from the Register involved the forging of a signature on professional documentation on more than one occasion. That conduct was fraudulent.

In assessing the Applicant’s evidence, the Panel considered the Applicant had done his best to tell the truth and to accept what he had done wrong. The Panel was prepared to accept at face value the Applicant’s evidence that the incorrect declaration in 2023 had resulted from carelessness rather than deliberate dishonesty. However, the Panel were of the view that the Applicant knew that he had previously been removed from the Register and was aware of his obligation to provide truthful and accurate information when completing the application form.

The Panel also noted that the Applicant did not appear to have been particularly well prepared for the hearing and that there was a lack of understanding as to the nature and extent of the information which required to be placed before the Panel in support of the application. The Panel recognised the Applicant was nervous. There was nothing negative in the Applicant’s demeanour, who engaged respectfully with the Panel throughout. However, greater engagement with and preparation for the process would have assisted the Panel.

There was an absence of relevant professional references, save for the material from the British Heart Foundation at pages 52–54. That material was not sufficient to assist the Panel in determining the question of the Applicant’s suitability for registration as a teacher. There had been no independent observation of, or feedback regarding the Applicant’s teaching. Nor had the Panel been provided with information from pupils, parents or the church by way of testimonials or other evidence concerning private tutoring.

The Panel noted the insight the Applicant had demonstrated in relation to that conduct, the acceptance that there was no excuse for the forgery and that it had represented a serious error of judgment. The conduct in 2009 inevitably gave rise to questions regarding the Applicant’s honesty and integrity. However, the Panel noted that the Applicant accepted responsibility for his actions and was able to explain what he would now do differently.

Notwithstanding that insight, the Panel was concerned by the Applicant’s subsequent completion of the application form in 2023, in which he provided an incorrect answer to the relevant declaration. The Panel was of the view that the Applicant’s continuing carelessness in completing an official form suggested that there remained underlying values issues in terms of paragraphs 1.4 and 1.5 of COPAC.

Fitness to Teach

The Panel considered that the conduct from 2009 was capable of remediation. However, the fact the Applicant had made a similar mistake in 2023, even if that mistake was properly characterised as a careless error, did not demonstrate remediation of the underlying concerns. The Panel took the view the Applicant had demonstrated a lack of sufficient regard for honesty and for the need to take care to ensure that only truthful and accurate statements were made in official documents relating to professional status.

The Panel considered that there was a pattern of similar conduct which, at its lowest, demonstrated naivety and carelessness and, at its most serious, was fraudulent. The Panel also recognised that there was an apparent motivation for making a false declaration and the Applicant’s admitted knowledge of the previous removal order.

Further, the Panel had been provided with no evidence of significant teaching-related remediation and there were no independently verified sources supporting the quality or competence of the Applicant’s teaching. Very limited information was available to the Panel in respect of the Applicant’s current competence. In all of these circumstances, the Panel determined that, as at 2023, the Applicant had demonstrated a lack of remediation.

In relation to the risk of recurrence, the Panel was unable to conclude that this was low. The Panel took the view that the Applicant’s assurances were insufficient when considered against the background of the repeated error in 2023.

In response to questions from the Panel, it was also apparent that there was an absence of current knowledge and understanding of the Scottish curriculum, the qualifications framework and current developments within Scottish education. The Panel determined that fitness to teach required more than an ability to inspire children. A teacher practising in Scotland required to be able to provide children and young people with the education necessary to progress towards national qualifications. This necessarily involved, amongst other matters, the preparation and completion of accurate professional and assessment documentation.

In that respect, the Panel considered that relevant training and professional development were lacking. The evidence did not satisfy the Panel that the Applicant presently had sufficient knowledge and competence to deal appropriately with the relevant phases of Scottish education and associated assessment and documentation requirements. It was essential that a teacher seeking registration in Scotland was appropriately familiar with the Scottish educational landscape.

The Panel went on to consider the public interest. It did not identify any public protection concerns. However, it determined that the public interest was engaged in respect of the need to maintain public trust and confidence in the teaching profession and to uphold proper professional standards.

The Panel considered that a reasonably informed member of the public would have concerns given that the fraudulent conduct which had led to the Applicant’s removal was not simply an isolated historical matter but had been followed by a further false declaration in 2023. Even accepting the Applicant’s explanation that the latter declaration had resulted from negligence and carelessness rather than deliberate dishonesty, a reasonably informed member of the public would expect a teacher to demonstrate the values and standards identified at paragraphs 1.4 and 1.5 of COPAC.

The Panel therefore had concerns as to whether the Applicant could presently act as an appropriate role model and model the necessary professional values and standards to children and young people.

The Panel ultimately determined that there remained a risk of repetition and that there were no workable or suitable conditions which could adequately address the concerns identified in relation to honesty and carelessness. The Panel also took account of the fact that the Applicant did not intend to undertake studies or teacher training in Scotland but instead intended to pursue a route to qualification in England.

Taking all of these matters together, including the risk of repetition and the public interest concerns arising from the Applicant’s failure to demonstrate the standards set out at paragraphs 1.4 and 1.5 of COPAC, the Panel was not satisfied that the Applicant was currently fit to teach.

Disposal

As the Panel determined that the Applicant is unfit to teach, in accordance with the terms of Article 18(2)(b) of the Public Services Reform (General Teaching Council for Scotland) Order 2011, it directed that the application for registration be refused.

Rule 2.10.6 outlines that a Panel may direct that the Applicant be prohibited from making a subsequent registration application until the expiry of such a period, not exceeding 2 years, as it may determine. In this case, the Panel directed that the Applicant should not be prohibited from making such an application.

Appeal

The Applicant will receive written notice of this decision within 28 days and has the right to appeal to the Court of Session against the decision within 28 days of the date of service of that written notice and has the right to right to lodge an appeal with the Appeals Board within 28 days where he can show that there are grounds to ask for the decision to be reviewed in terms of the Fitness to Teach Panel having either: