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Decoding Judgements: Patient Consent and Medical Intervention in Re T [1992] EWCA Civ 18

2 August 2024 | CaseSnappy Team

An image of a blood test tube with a blood dropper attached to it.

Introduction

Hey there, CaseSnappy community! The gavel is on the stand once more for our Decoding Judgements series. Our spotlight now turns towards the crossroads of medical ethics and law, focusing on the controversial case of Re T [1992] EWCA Civ 18.

Under the Microscope: The Case Facts

The drama unfolds with Miss T, a pregnant former Jehovah’s Witness who finds herself hospitalised after a traffic accident. Complications with pregnancy and pneumonia necessitated a caesarean section, whereupon Miss T refused a potentially lifesaving blood transfusion. Despite debates shaped by narcotic influence and potential coercion from her mother, her condition deteriorated, leading the hospital to seek court intervention for necessary transfusions.

The Diagnosis: The Issues

Amidst the crisis loomed significant questions: was Miss T's refusal of blood transfusion under influence and medication legally valid? Should her prior refusal prevent medical practitioners from administering a potentially life-saving treatment?

Operating Table: Decision Judgement

The court found limited capacity in Miss T's consent, considering the influence of medication and her mother. It ruled in favour of the doctors administering blood transfusions. The court found her immediate health paramount, and deemed the intervention as lawful despite her initial refusal.

Lord Donaldson MR stated: "The law requires that an adult patient ... must consent if medical treatment of him is to be lawful ..." and noted that this consent may be influenced by the patient’s physical and mental condition. Butler-Sloss LJ emphasised that capacity and genuine consent are separate but may overlap, potentially weakening a patient's resistance to undue influence.

CaseSnappy: Illuminating Baffling Cases

The case of Miss T sheds light on the tangled web of autonomy, medical ethics, and consent in health law. It asserts that patient's autonomy isn't absolute, especially under specific circumstances, and medical practitioners are obligated to act in their patient's best interest. Our Decoding Judgements saga continues, endeavouring to untangle the complex threads of legal quandaries, providing insight for law students and other legal aficionados.

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