Interesting "criticism" the phrase: "Not good at following instructions". What a classic example of vague generalisation. Yet the dead student is damned by that sentence.
Having had the requirement to read through many progress report sheets written by all grades of flying instructors, I would say that 75% are poorly written and reflect on the instructors lack of schooling in simple report writing.
In fact I am certain that many flying schools that train instructors do not adequately cover (if at all) the subject of concise and accurate writing up of students progress reports. Some reports that I have seen have a childish style of writing.
Example: "Robert - you must learn your checks. You must learn to keep your hand on the throttle at all times. Robert - you must try harder to to concentrate during the downwind leg. You keep on drifting inwards." Or:
"Bill improving but still needs to watch his speeds on final"
What a meaningless and ineffectual piece of report writing.
It concerns me that badly phrased sentences may convey a different meaning to different people - and an apparently innocuous phrase as the one above "Not good at following instructions" is seized upon by the judiciary or a cunning legal eagle and the poor bloody student is damned for life as a rebel.
CFI's have a direct responsibility to the student to ensure that the instructor writes a fair and reasonable assessement of each dual flight. I believe that where criticism of the student's ability is entered by an instructor in the student's record, the student should be offered the opportunity to read his record and have redress if he considers the instructor's comments do not represent the facts. The same principle should apply to the progress reports written up by a check pilot or flight simulator instructor.