28 Based upon the standard of disclosure set out in Montgomery , 29 one would think that there were four key aspects relevant to the decision in Grimstone : (i) its confirmation that the Bolam standard no longer applied in determining what information a patient should be given; (ii) its requirement to disclose material risks, those being risks that were likely to be significant to a reasonable patient, or this particular patient; (iii) its inclusion of the requirement to disclose reasonable alternative or variant treatments; and (iv) its requirement that patients be made aware of the comparative risks and benefits of the proposed treatment and reasonable alternatives or variants of it.
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Grimstone v Epsom and St Helier University Hospitals NHS Trust: (It's Not) Hip to Be Square.
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