NaCCA Deputy Director-General replies GTEC on ‘invalid SMC Dr’ title and says until a court rules otherwise, he’ll continue to use his title

Consistency and Fair Administrative Practice I note with concern that GTEC, under your leadership, has previously issued a formal attestation, My Ref. No.: DRO/2025/05/03, dated October 2025, validating a similar SMC doctoral credential (Doctor of Finance) awarded to Mr. Kingsley Kwesi Kwabahson. That attestation, duly signed by your office, explicitly states that “the degree of Doctor of Finance awarded by the Swiss Management Centre, Switzerland, is comparable to a Doctorate degree in the relevant subject area, awarded by recognised tertiary education institutions in Ghana.” It is therefore procedurally inconsistent and administratively untenable for GTEC to now declare that “all certificates issued by SMC are invalid.” The two communications, issued within a month of each other by the same authority, cannot logically coexist without implying selective application of administrative discretion or a failure of procedural uniformity. On the Nature of the Degree Designation (“Doctorate” vs “Doctor”) The attempt to distinguish between “Doctorate of Business Administration” and “Doctor of Business Administration” is academically misconceived and linguistically unfounded. In academic taxonomy, “Doctorate” defines the qualification level, whereas “Doctor” denotes the title borne by a holder of that qualification. The two expressions are semantically and functionally interchangeable within global higher education practice. Internationally, both formulations are employed by leading institutions: • Doctor of Business Administration (DBA) – Harvard University; University of Manchester; University of South Africa (UNISA). • Doctorate in Business Administration (DBA) – Swiss Management Centre University; Walden University; and other accredited universities.Therefore, any attempt to invalidate a qualification based on nomenclatural variation lacks academic foundation and undermines the equivalence principles which GTEC itself applies when evaluating foreign qualifications. On Alleged “Irregularities” in the Academic Transcript The observations made by GTEC regarding the structure and format of my transcript are factually misplaced and academically non-comparative. (i) Credit and Semester Structuring SMC University operates under the European Credit Transfer and Accumulation System (ECTS), not the Anglo-American semester-credit model. Consequently, credit volumes, progression, and grade representation follow continental European norms rather than Ghanaian ones. Under ECTS, doctoral-level modules typically aggregate 60–90 credits per academic phase, with research components carrying bulk credits equivalent to cumulative learning effort, hence, totals exceeding 600 credits are both standard and valid under that framework. (ii) Numerical Grading Format The numerical grading system observed (e.g., 3.8, 3.7) aligns with ECTS-GPA conventions, which express proficiency levels on a 4.0 or 5.0 numeric scale. These are converted into letter grades for comparative referencing when required. This hybrid notation is not “irregular” but reflects cross system equivalence coding, a practice long recognised by NAB and other credential evaluation authorities worldwide. (iii) Thesis Course Coding Doctoral theses are, by international convention, standalone research components recorded independently of taught course modules and not typically assigned discrete course codes or credit weights on transcripts. The absence of such coding is standard in most European doctoral records and does not indicate any academic anomaly or incompleteness. Hence, each of the alleged “irregularities” is explained by systemic academic differences, not by inaccuracy or fraud. Any evaluation purporting to apply Ghanaian credit and grading conventions to a Swiss or European doctoral transcript is inherently methodologically flawed and lacks cross system validity. On Institutional and Programme Identification The Commission’s observation regarding the use of “Swiss Management Centre” and “SMC University” fails to appreciate the corporate and academic structure of the institution. “SMC University” is the academic entity of the Swiss Management Centre Group, legally registered and recognised under Swiss jurisdiction, and duly listed in the European tertiary education registry. The use of both names interchangeably in documentation reflects legitimate institutional evolution, not inconsistency or fraud. Moreover, the National Accreditation Board (NAB), now subsumed into GTEC, expressly clarified in its public notice of 24th August 2020 that “all students enrolled before 31 August 2018 possess valid credentials which are recognised, unless incontrovertible evidence of fraud is established.” My enrolment, study, and graduation occurred squarely within that protected regulatory window, and there has been no allegation or evidence of fraud in my case. On Programme Evaluation and Regulatory Integrity If GTEC now asserts that SMC qualifications are “invalid,” principles of transparency and administrative justice require disclosure of the Committee of Experts’ report that evaluated SMC’s doctoral programmes, which was submitted to the NAB Board and formed the basis for its original recognition decision in 2012. I therefore respectfully request that GTEC furnish: • The Committee’s evaluation report on SMC’s doctoral programme; and • Any Board resolution or statutory instrument that lawfully nullified prior recognition. In absence of such disclosure, the current directive may be deemed arbitrary, ultra vires, and contrary to the doctrine of legitimate expectation recognised under Ghanaian administrative jurisprudence. Legal Foundation and Retrospective Invalidity Under Section 70(1) of Act 1023, GTEC’s mandate to evaluate and authenticate qualifications does not extend to retrospective nullification of academic awards lawfully earned under the authority of a then-competent regulatory body (NAB). No provision within Act 1023 or any other Ghanaian statute confers upon the Commission the power to unilaterally invalidate academic credentials retrospectively without a judicial pronouncement or due statutory process. Accordingly, GTEC’s directive purporting to revoke recognition and prohibit the use of an academic title earned in good faith under NAB’s regulatory dispensation is without legal foundation. It amounts to an administrative overreach, inconsistent with the principles of legitimate expectation, accrued rights, and non-retroactivity in law. Conclusion and Reservation of Rights Accordingly, and until a court of competent jurisdiction rules otherwise, I am unable to comply with the Commission’s directive. I shall, in good faith and consistent with NAB’s 2020 affirmation, continue to use the academic title “Dr.”, a title reflecting a validly earned, lawfully conferred, and previously recognised doctoral qualification.