... patients, a duty of care is implied between a healthcare professional and his patient, except where private treatment is sought. The difficulty in this area arises in respect of the standard of care required from a practitioner towards his NHS patients and on establishing causation. As far as medical malpractice and professional accountability is concerned the case of Bolam v Friern Hospital Management Committee2 is central. In this illustrious and redoubtable case, the plaintiff was a manic-depressive who was given electro-convulsive therapy. Most treatments include a range of side effects from minor to major; In Bolam's treatment reactions involved seizures which could cause fractures of the bones. He suffered very severe fracture on his pelvis. Measures such as restraint and relaxant drugs could reduce those dangers. However, the plaintiff via his representatives was not given any routine warning about the dangers involved in his treatment neither information on the available ...

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