§ PUBLISHED JUDGMENT · 2021

Khan v Meadows

[2021] UKSC 21·Supreme Court of the United Kingdom·18 June 2021

A GP negligently failed to arrange proper testing, so a woman wrongly believed she did not carry the haemophilia gene and went on to have a son with haemophilia who also had autism. The Supreme Court held the GP was liable only for the haemophilia-related costs, because the purpose of the advice was to guard against that risk, not the unrelated risk of autism.

Outcome

Claim failed

Sum stated in judgment

£1,400,000

Claim type

GP Negligence

Decided

Appeal decision

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§ WHAT HAPPENED

The facts, in brief.

Defendant: Dr Hafshah Khan (general practitioner)

Injury: Wrongful birth: son born with severe haemophilia (which the mother would have avoided by termination had she been correctly tested) and, unrelatedly, autism

Specialty: General practice / Genetic counselling · England

§ WHAT THE COURT SAID

In the judgment’s own words.

“We would dismiss the appeal.”
[2021] UKSC 21 at [69] · read the full judgment

The money

£1.4m was the agreed value of the extra costs attributable to haemophilia alone ([73]). The trial judge had awarded £9m including autism-related costs ([19]); the Court of Appeal reduced it to the haemophilia figure and the Supreme Court dismissed the mother's further appeal, so the £1.4m stood.

§ WHY IT MATTERS

What this case shows.

Damages are limited to losses falling within the scope of the duty the doctor undertook. Even where negligence clearly led to a child's birth, unrelated conditions that the advice was never meant to address are not recoverable.

About gp negligence claims →

§ MORE GP NEGLIGENCE JUDGMENTS

Claimant succeeded

Philipa Hodgson v Dr Daniel Hammond & Anor

[2025] EWHC 1261 (KB)·2025·Liability decided at trial

Ms Hodgson saw a locum GP who suspected pelvic inflammatory disease but did not examine her or arrange urgent follow-up, and a second GP reviewing her blood results by telephone did not refer her for examination. The delay in treatment led to an abscess, removal of a fallopian tube and chronic pelvic pain.

When a GP suspects a serious infection, the court expects an examination or urgent referral to rule it out, and a telephone review of test results does not replace that. Both GPs were held liable, with damages to be decided separately.

Claimant succeeded

Gurmukh Gahir v Dr Ayodele Olusgun Ola

[2024] EWHC 390 (KB)·2024·Liability decided at trial

Mr Gahir went to his GP with fever, severe headache, nausea and confusion; the GP diagnosed migraine, and he was not admitted to hospital until 55 hours later, when herpes simplex encephalitis was treated with acyclovir. The judge found the combination of fever, headache and confusion required urgent hospital referral and that earlier treatment would have left him far less disabled.

Fever, headache and confusion together are a recognised red flag for brain infection, and a GP who attributes them to migraine without arranging urgent admission may be found negligent. The judge accepted the family's account of the patient's confusion during the consultation.

Claim failed

Edward Graham v Dr Simone Altaf

[2023] EWHC 156 (KB)·2023·Liability decided at trial

A three-year-old was diagnosed with tonsillitis by a GP registrar, deteriorated over the next two days and was then referred to hospital, where meningococcal meningitis was diagnosed. The court found no causative breach of duty and dismissed the claim.

Meningitis claims against GPs often fail because early symptoms genuinely resemble common childhood infections; the claimant must show both that the GP fell below a reasonable standard and that earlier referral would have changed the outcome.

All gp negligence judgments →

Contains information licensed under the Open Justice - Licence v2.0. Judgments from Find Case Law, The National Archives. Summaries are ours; amounts only where printed in the judgment.

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