Birch v University College Hospitals NHS Trust [2008] EWHC 2237, [2008] All ER (D) 113 (Sep)
There will be circumstances where the duty to inform a patient of significant risks will not be discharged unless he is made aware that fewer, or no risks, are associated with another procedure. Unless the patient is informed of the comparative risks of different procedures, he will not be in a position to give fully informed consent to one procedure rather than another.