Complaint to the GMC about Mandatory Vaccines

by Dr. Graeme Munro-Hall and Dr. Lilian Munro-Hall

We are retired general dental practitioners and former registrants of the GDC, Dr Graeme Munro-Hall (GDC 45121) and Dr Lilian Munro-Hall (82913). As avid cruisers and potential guests of Saga cruises we have written to Saga Cruises about their mandatory COVID-19 vaccination policy for their guests. No reply has been received yet. We, who have declined these vaccines, are being discriminated against by Saga Cruises on the basis of not wanting to participate in a particular form of experimental medical treatment. The FDA describes these vaccines as “Investigational” and “experimental”.

Extracts of the letter are below.

We are seeking advice as to whether it will be an appropriate course of action to request that the General Medical Council take action against Saga Cruises, and specifically Nigel Blanks, the Chief Executive Officer of Saga Cruises, for, in effect, practicing medicine without a licence while being unqualified and unregistered to do so thereby potentially endangering the health and wellbeing of UK citizens.

The General Medical Council must take steps to instruct Saga Cruises and Nigel Blanks to cease and desist immediately from the Practice of Medicine .

We feel this is putting undue pressure on people to undergo an experimental medical treatment.

The Nuremberg Convention in article 1 states that

any person involved in (medical treatment) must be able to exercise free power of choice and voluntary consent is absolutely essential and that this must be given without any element of duress. Experimental medical treatment requires that the subject know the nature, duration, purpose of the experiment, the method and means by which it is to be conducted, all inconveniences and hazards reasonably to be expected and the effects upon health or person which may possibly come from participation in the experiment.

On January 20th this year, Nigel Blanks, Chief Executive Officer for Saga Cruises, published a statement in which he, on behalf of Saga Cruises, announced the introduction of mandatory COVID-19 vaccination on all guests wishing to partake in a Saga Cruise.

This was followed by an extensive media advertising campaign announcing that all guests must be vaccinated against COVID-19 in order to travel with Saga Cruises.

This goes against the recommendations with regard to mandatory vaccination of:

  • UK Govt
  • The Council of Europe

It also involves:

  • Unquantifiable health risks by putting undue pressure on people to participate in the largest medical experiment in human history.
  • Breaches of human rights and the tenets of Informed Consent and is in violation of article one of the Nuremberg Code
  • Discrimination on philosophical, religious, medical and age grounds.

What Saga Cruises are doing is practising medicine.

Definition of the Practice of Medicine

A third party is involved in the Practice of Medicine when medical decisions are taken out of the hands of individual doctors and are instead controlled, even in part, by non-physicians, Saga Cruises in this instance. Third parties should not meddle with and effectively, directly or indirectly, control or in some way influence the course of medical practice.

The Practice of Medicine involves the diagnosis, treatment, PREVENTION, cure, or relieving human disease, ailment, defect, complaint or other physical or mental condition by attendance, ADVICE, diagnostic test OR OTHER MEANS or offering, undertaking, attempting to do or holding oneself out as able to do so, any of these acts.

(The Free Dictionary – legal definitions.)

The statement outlined in bold type in their document,

We have taken the decision to introduce the requirement that all guests must be fully vaccinated against COVID‑19 at least 14 days before sailing with us.

is clearly and unequivocally practising medicine by making vaccination against COVID-19 mandatory for their guests.

If Saga make access to Saga services offered by Saga Cruises available only after specific mandatory medical treatment, it assumes the responsibility of making sure that the mandated medical treatment is:

  • Safe
  • Effective
  • Non-discriminatory and given with full informed consent
  • Proportionate to the risk following a risk and benefits evaluation.

When mandating a medical treatment, Saga Cruises and Nigel Blanks have a Duty of Care to those affected.

They cannot hide behind any declarations of safety and efficacy of any regulatory body or Government department or pharmaceutical company as they must do their own risk and benefit evaluation based on the published and verifiable facts.

Failure to do this is wilfully and deliberately putting their guests health and wellbeing at risk.


The Food and Drug Administration (FDA) of the USA, have called the mRNA vaccines of Moderna and Pfizer as well as the AstraZeneca vaccine an “Investigational drug”.

Quoting the FDA, “Investigational drug also called an experimental drug and is being studied to see if a disease or medical condition improves while taking it.”

None of these drugs has approval to be used as a vaccine and has passed the safety and efficacy standards set by the FDA for vaccines.

Saga Cruises are mandating for their guests a medical treatment that is in the words of the regulator, “experimental”.

Many medical professionals and nations have expressed deep concerns about the safety of the COVID-19 vaccines. Researchers from the School of Public Health University of California found that 65% of healthcare workers surveyed will refuse a vaccine until they can review the data and be sure that it is proven to be safe.

COVID-19 is primarily a disease of the upper respiratory tract and there is a correlation between the flu jab and an increase in upper respiratory tract infections. This has been reported in the BMJ.

A January 2020 study published in the journal Vaccine also found people were more likely to get some form of coronavirus infection if they had been vaccinated against influenza.

The correlation between the flu jab and COVID-19 deaths has been verified by scientific analysis.

A January 2020 study published in the journal Vaccine also found people were more likely to get some form of coronavirus infection if they had been vaccinated against influenza.

Whilst correlation is not proof of causation it does call into question the safety of such vaccinations when mandated for predominantly elderly guests who are the target group for flu vaccination campaigns. This would make them be more likely to have received a flu jab and, therefore, have a higher risk of contracting COVID-19.

Some countries have either banned or restricted the use of the AstraZeneca vaccine as of February 6th 2021. Switzerland has a total ban on this vaccine and France, Germany, Holland, Italy, Poland, Spain and Sweden have restrictions on administering the vaccine based on advancing age.

The reasons given are “Insufficient data regarding the safety and efficacy of the AstraZeneca drug”. This does not include the data that this vaccine may be less effective for the new COVID-19 variant.

For Saga Cruises to mandate treatment that may include the administration of the AstraZeneca vaccine seems to us an abdication of the duty of care they owe to their guests.

The mRNA vaccines developed by Pfizer and Moderna are a novel technology.

The long-term effect of such drugs is completely unknown. Anyone taking the drug is taking part of a long-term trial for the safety and efficacy of the drug, whether they are aware of the fact or not. It is entirely experimental in nature.

These mRNA vaccines are designed to instruct cells to produce certain proteins by the insertion of synthetic mRNA or DNA into the cells. Moderna does not call its drug a vaccine but “Operating Platform – The Software of Life”. The chromosomal DNA of the cell is presumably the ‘hardware’. However, once this “software” is downloaded and installed into the cell, there is no way of uninstalling it.

The long-term consequences on health are entirely unknown.

Many scientists and medical professionals have voiced their concern about the hypothesised but realistic side effects that include male and female infertility, cardiovascular disease and, in an FDA paper on COVID-19 vaccine side effects, increased auto-immune disease, strokes, encephalitis, birth defects, Kawasaki disease and death.

The Front Line Doctors of America in a White Paper call the brand-new technology utilising messenger RNA “The largest experimental medication program in our history”. “No vaccine” based on this technology, they say, “has ever been approved for any disease, or even entered final-stage trials until now, so there’s no peer-reviewed published human data to compare how mRNA stacks up against older technologies.”

There have been no independently published animal studies. Previous coronavirus vaccines developed over decades have consistently failed in animal trials with the death of their subjects (and two children).

These novel vaccines were developed and produced in a matter of months rather than years as is usually the case. The target in the cell for the mRNA vaccines is similar to gamete (sperm) production instruction in males and mammalian placenta development in females. It is unknown if the vaccines will have an effect on human fertility but is a possibility as admitted by the UK Government in a 10-page report last year stating that it is “unknown whether COVID-19 mRNA vaccine has an impact on human fertility”.

While this will not be an issue for the majority of Saga Cruises guests personally, it is a cause of grave concern to the population as a whole and a significant issue for the crew. The paper also warned that the vaccine should not be used in pregnant or nursing women.

Another cause for concern is that vaccine recipients may become more vulnerable to the COVID-19 virus as prior coronavirus vaccines have failed due to the scientific phenomenon known as pathogenic priming that makes the vaccine recipient more likely to suffer a sudden fatal outcome due to massive cytokine storm when exposed to the wild virus.

Pathogenic Priming is when, rather than enhancing your immunity against the infection, exposure to a virus or vaccine enhances the virus’s ability to enter and infect your cells, resulting in more severe disease.

This is something that has been seen in previous vaccines for coronaviruses like COVID-19 and the reason none has ever previously made it to the market.

An immunologist, Dr Hooman Noorchashm MD PhD, in an open letter to the FDA states that there is a real possibility that those with pre-existing antigens to the virus in their tissues could be harmed, especially those with pre-existing cardiovascular disease. The length of time, 10-20 days, following vaccination before symptoms manifest (death) make it unlikely that the deaths or any severe reactions will be attributed to the vaccine.

COVID-19 is a virus with a particular affinity to heart tissue so mRNA vaccines could direct an antigen-specific attack on the heart itself.

In other words, the possibility of triggering an antibody-dependant enhancement or ADE event is very real and remains a significant concern.

Another significant concern is that the constituents of the vaccines can cause anaphylactic reactions which can be fatal. Polyethylene Glycol (PEG) is one such substance and there are others linked to nerve damage which would account for the many videos on social media showing individuals shaking uncontrollably after receiving a COVID-19 vaccine.

These reactions appear to be at a higher rate than is normally associated with vaccines. The CDC and the UK Government have issued guidance that anyone with an allergy to PEG or any of its near relatives should not receive a vaccine.

Saga Cruises would thus be discriminating against guests with pre-existing allergies. Some guests will have, as yet, undiagnosed allergies and may suffer harm as a result of the mandatory administration of these vaccines.

The CDC admits to one in 36 doses of the mRNA vaccine causing an adverse event strong enough to warrant medical attention or being unable to perform daily duties:

As of January 29th 2021 death was 4.45%, permanent disability was 1.39% and life-threatening conditions were 3.4% of these adverse events according to CDC released figures.

These vaccines can also cause a reduction of the immune system to respond to threats up to seven days after the initial dose as seen below:

This could explain, in part, the increase in over 80s UK COVID-19-related deaths following vaccination.

Looking at the actual numbers brings the stark reality of the unfolding tragedy into focus.
In the eight weeks before vaccination started on 08-12-20, the average number of deaths of the 80+ group was 760 per week.
In the eight weeks after vaccination started (up to 27-01-21) the average number of deaths in the 80+ group was 1838 per week.
This is nearly 2.5 times more than before after the vaccination programme started.
More simply put, for every two persons who died in the 80+ group prior to vaccination, five persons died after vaccination started.
To make it even more dramatic, in the first 10 months of 2020, the COVID-19 deaths for 80+ group was 16420. In the next three months up to 27-01-21 the deaths were 21820.
During the three month period ending in January 2021, there were 5400 more COVID-19 deaths than in the first 10 months of 2020. In the 80+ group.
The daily death rate of the 60-79 age group has also seen an increase.

In Conclusion: COVID-19 vaccines carry a significant risk to life and health in the short-term and have unknown long term-consequences that may be irreversible.

By mandating these vaccines to guests, both Saga Cruises and Nigel Blanks are coercing their guests to have a medical treatment that may prove to be detrimental to their health and well-being.


It is also within the duty of care of Saga Cruises and Nigel Blanks to make sure that any proposed mandatory medical treatment is effective. For this, reliance has to be put on the data provided by the pharmaceutical companies and the question arises whether the data is valid and can be trusted.

Unfortunately, the pharma industry as a whole has a public history of being economical with the truth if it served their perceived economic interests.

For example (but they are by no means alone) in 2010 Robert G. Evans, PhD, Centre for Health Services and Policy Research Emeritus Professor, Vancouver School of Economics, UBC, published a paper that is available on PubMed titled Tough on Crime? Pfizer and the CIHR.

In it, he outlines the fact that, Pfizer has been a “habitual offender,” persistently engaging in illegal and corrupt marketing practices, bribing physicians and suppressing adverse trial results. Since 2002 the company and its subsidiaries have been assessed $3 billion in criminal convictions, civil penalties and jury awards. The 2.3-billion settlement set a new record for both criminal fines and total penalties.

The industry has been fined $14 billion. AstraZeneca have been fined $1.1 billion.

It is best to bear these facts in mind when assessing information provided by the industry. The bar was set exceptionally low for the companies in developing these vaccines. All they were required to do was to show a reduction in the severity of symptoms in 50% of cases.

They were not designed to:

  • Reduce the incidence of COVID-19.
  • Reduce the hospitalisation rate.
  • Reduce death rates.
  • Reduce ‘transmissibility’ of the virus after vaccination.

At the same time the pharmaceutical industry demanded and received a total blanket immunity against any liability with regards to the vaccines.

The individual and the taxpayer will bear the risks associated with the vaccines.

The efficacy claims of 95% for the Pfizer vaccine is a Relative Risk Reduction. The more meaningful Absolute Risk Reduction is nearer 0.4%. Another concern was the way the data was manipulated to exclude certain groups which would bring the Relative Risk Reduction to under 30%.

The same criticisms can be laid at the door of Moderna as well.

The efficacy of the AstraZeneca vaccine has been called similarly into question by German doctors who estimate the vaccine to be 8% effective in certain groups.

However, it could be argued, how effective do the vaccines need to be given that the CDC estimate of the Infection Fatality Rate (IFR) is remarkably low:

  • 0-19 years 99.997% survival rate
  • 20-49 years 99.98% survival rate
  • 50-69 years 99.55 survival rate
  • 70+ years 94.6% survival rate

In conclusion: Taking into consideration all the above information it is clear that the vaccines offer only limited protection against COVID-19.

All the information outlined here should have been considered by Saga Cruises and Nigel Blanks in a robust risk/benefit analysis before pressurising people into experimental medical treatments.

Discrimination, Human Rights and Informed Consent

UK vaccine minister, Nadhim Zahawi, has stated that the UK Government has no plans for a ‘vaccine passport’ as that would be discriminatory. Previously, he had ruled out any chance of the Government making COVID-19 vaccines mandatory. Forcing guests to have a COVID-19 vaccine is inherently discriminatory. Saga Cruises, in demanding that guests have a COVID-19 vaccine, is behaving in an inherently discriminatory fashion.

The United Kingdom remains a member state of the Council of Europe.

Resolution 2361 of the Parliamentary Assembly of the Council of Europe passed on 29-01-21 has this to say about COVID-19 vaccines.

COVID-19 vaccines: ethical, legal and practical considerations.

  • Ensure that citizens are informed that the vaccination is NOT mandatory and that no-one is politically, socially or otherwise pressured to get themselves vaccinated if they do not wish to do so themselves.
  • Ensure that no-one is discriminated against for not having been vaccinated due to possible health risks or not wanting to be vaccinated.
  • Transparent information on the safety and possible side effects of vaccines should be distributed.

The demands of Saga Cruises and Nigel Blanks are in direct contradiction of the statements of the UK vaccine minister and the Council of Europe Resolution 2361.

Saga Cruises is discriminating against whole groups of potential Saga Cruises guests:

  • Those with religious objections to the vaccine, i.e., Roman Catholics due to the use of aborted foetal tissue in the manufacture of the vaccines.
  • Disability and previous medical history will preclude many from having the vaccines. For example, some may have medical conditions such as previous allergies to vaccine.
  • Being old is enough to be a contra-indication to vaccination due to an age weakened immune system, poor nutritional status, etc.

Saga Cruises are discriminating against the Human Rights of potential guests on grounds of Religion, Medical History/Disability and Age.

This may be contrary to the Equality Act of 2010 and the appropriate advice is being sought. Aggravated damages can be awarded by a court if it judges the offence to be carried out in a heavy-handed matter as well as damages for injured feelings.

A spokesperson for Saga Cruises said that the crew of Saga ships were not forced to have vaccines only the guests. Perhaps this is because Saga Cruises management are aware that such a requirement might run afoul of employment law.

Informed Consent to any medical procedure is mandatory and relies on the transparency and accuracy of the information. The duty to impart this information about the vaccine is on the vaccinator but also applies to Saga Cruises and Nigel Blanks who have mandated the vaccine for their guests.

The Universal Declaration on Bioethics and Human Rights states that any preventive, diagnostic and therapeutic medical intervention must only be carried out with the prior, free and informed consent of the person concerned, based on adequate information.

Recipients of the vaccines need to be told:

  • The vaccines are experimental.
  • mRNA vaccines rely on a novel synthetic biology with an unknown long-term outcome.
  • The risks and benefits of the vaccines will not be known until at least 2023.
  • The risks relating to COVID-19 as applied to them.

UK guidelines to vaccinators state:

  • The person giving the consent must be appropriately informed with access to the information.
  • Consent needs to be given voluntarily and without coercion, undue pressure or deceit.
  • Consent is a legal requirement and the patient’s views must be respected and consent sought.
  • The patient must understand what they are consenting to.

Saga Cruises and Nigel Blanks cannot escape the duty of care they owe their guests by seeking proper informed consent before proceeding with their mandatory vaccination.

Saga Cruises and Nigel Blanks need to be transparent and publish the risk and benefit analysis for guests regarding COVID-19 vaccines.

In conclusion: The imposition of mandatory vaccines by Saga Cruises and Nigel Blanks is applying undue pressure and coercion which is a violation of the principle of Informed Consent and is discriminatory.

Saga Cruises should stop coercing potential guests into undergoing experimental medical treatments.

There is not enough data about the safety and the efficacy to make an informed decision about receiving these vaccines.

Dr. Graeme Munro-Hall (GDC 45121) and Dr. Lilian Munro-Hall (82913) are retired general dental practitioners and former registrants of the GDC. They can be contacted at

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October 2022
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