Following the directive to Justice Ray Achoanya Ayam, the Acting Deputy Director-General of the National Council for Curriculum and Assessment (NaCCA) under the Ministry of Education, to stop using an “invalid Dr” title obtained from the Swiss Management Center (SMC) University from Switzerland, he has responded to that directive from the Ghana Tertiary Education Commission (GTEC).
According to the NaCCA Acting Deputy Director-General, until a court of competent jurisdiction rules otherwise, he is “unable to comply with the Commission’s directive. I [Ayam] 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,” he stated in a letter dated November 11, 2025, in a response to the GTEC directive.
In his response letter, a copy of which has been seen by Graphic Online, Justice Ray Achoanya Ayam raises issues of consistency and fair administrative practice in GTEC’s handling of the whole SMC matter.
Ayam also touched on GTEC’s concerns on the nature of the degree designation (“Doctorate” vs “Doctor”), on the alleged “Irregularities” in the academic transcript, the credit and semester structuring at SMC, the numerical grading format, the thesis course coding, the institutional and programme identification, the programme evaluation and regulatory integrity and concludes with the reservation of his rights in the whole matter.
From those arguments [full copy attached below], he insists that “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 then National Accreditation Board (NAB) Board and formed the basis for its original recognition decision in 2012.”
He is therefore asking that GTEC furnish him with the “Committee’s evaluation report on SMC’s doctoral programme; and any Board resolution or statutory instrument that lawfully nullified prior recognition.
To him, in the 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.”
Attached below is a full copy of Justice Ray Achoanya Ayam’s response to GTEC on the matter
RE: REBUTTAL TO DIRECTIVE ON USE OF ACADEMIC TITLE (“Dr.”) AND REQUEST FOR DISCLOSURE OF EVALUATION BASIS
I acknowledge receipt of your correspondence dated 10th November 2025 concerning the evaluation of my Doctor of Business Administration (DBA) credentials awarded by the Swiss Management Centre (SMC) University. I wish to respond respectfully yet firmly, guided by the principles of administrative fairness, consistency, legality, and due process as enshrined under the Education Regulatory Bodies Act, 2020 (Act 1023) and the broader framework of Ghanaian administrative law.
- 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.
I remain committed to cooperating with the Commission in the spirit of transparency, fairness, and respect for institutional integrity, while reserving all legal rights and remedies available to me under Ghanaian law.
Writer’s email: [email protected]