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A London-based businessman has become the first person to be successfully prosecuted under the 1998 Education Reform Act for falsely claiming that his tutorial college could award legitimate degrees. Mark Chhatlani, director of the Western Governors Graduate School Ltd, of 10 Oxford Road, Wealdstone, Harrow, pleaded guilty last month to three offences under the Education Reform Act, the Trade Descriptions Act and the Business Names Act. He was fined Pounds 1,800 by Harrow Magistrates' Court and ordered to pay ?2,674 in costs.