§ GUIDE · PRIVATE CARE

Paid for private care.
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Private care is not a separate legal system, but it changes who you claim against. In the eight judgments here the defendant was often the individual consultant rather than the hospital, and in one case the hospital escaped liability entirely. Six succeeded.

Judgments read

8

Claimant succeeded

6 of 8

Largest sum stated

£1.2 million

Usual defendant

The consultant

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§ BEFORE YOU GO FURTHER

For a private-care claim, these things usually need to be true

  • The treatment was at a private hospital or clinic, or by a consultant seeing you privately.
  • The care fell below the standard: a missed step, a delayed response, an operation that should not have happened, or consent that was not properly taken.
  • The failure caused the injury.
  • It happened within the last three years, or you only recently found out.

In private care the consultant is usually an independent contractor. Alexander shows the hospital can be cleared while the doctor is held liable; Healey shows both can be, with responsibility apportioned.

§ 01

Who is liable

Alexander v HCA International: after a private ERCP the preventive drug was never prescribed; judgment for £550,000 against the gastroenterologist, and the claim against the hospital dismissed because he had not instructed the nurses. Healey v McGrath: death after an unrecognised leak at a Ramsay hospital; the hospital settled the widow's claim for £1.2 million and the court ordered the surgeon to bear 75%.

§ 02

Consent in private practice

Thefaut v Johnston: a spinal surgeon at a private hospital overstated the benefits and understated the risks of a disc operation; the claim succeeded on consent although the surgery itself was competent. Plan v El-Amir: a 79-year-old persuaded to have a lens implant at a private eye hospital without proper consent, then left with untreated raised eye pressure for five weeks; the surgeon was found negligent and she lost all sight in that eye.

§ 03

Technique and timing

Thomas v Curley: bile duct injured during private keyhole gallbladder surgery and poor monitoring on readmission; £92,391 upheld on appeal. Lesforis v Tolias: a blood thinner given within hours of spinal surgery at a Harley Street clinic caused permanent impairment. Tarrant v Monkhouse failed: a sleeve leak at a Spire hospital was a recognised complication with no breach. Tosh v Gupta failed on consent for a haemorrhoidectomy.

§ 04

What is different in practice

The consultant's own indemnity insurer, rather than NHS Resolution, usually defends the claim. Records may be split between the hospital and the consultant's private practice. A solicitor will identify every potential defendant at the outset so that nothing is missed.

§ THE JUDGMENTS BEHIND THIS GUIDE

The eight judgments behind this guide.

Every one a published decision of the courts of England and Wales, linked to its source.

Claimant succeeded£550,000

Alexander v HCA International Limited & Anor

[2026] EWHC 1284 (KB)·2026·Liability decided at trial

A patient developed life-threatening pancreatitis after a gallstone-removal ERCP. The judge found the consultant never prescribed or instructed the standard preventive diclofenac suppository, so it was not given, and entered judgment for £550,000 against him.

Failing to give a recognised prophylactic drug before a procedure can be negligent even in private care. The prescribing doctor, not the hospital, carried the liability here.

Claimant succeeded£1.2M

Healey v McGrath & Anor

[2024] EWHC 1360 (KB)·2024·Liability decided at trial

Mr Healey died nine days after bowel cancer surgery at a private hospital when a leak at the surgical join was not recognised in time. The hospital settled the widow's claim for £1.2 million and the court ordered the surgeon to bear 75% of it, finding his failure to diagnose the leak the principal cause of death.

Post-operative deterioration after bowel surgery must prompt urgent consideration of a leak. Both the private hospital and the individual surgeon can be liable, with the court apportioning responsibility between them.

Claimant succeeded

Thefaut v Johnston

[2017] EWHC 497 (QB)·2017·Liability decided at trial

Mrs Thefaut was told her disc operation had about a 90% chance of curing her leg pain and would probably settle her back pain, with tiny risks. Green J found the real prospects and risks were materially different, that she was not properly informed, and that the claim succeeded on consent although the surgery itself was not negligently performed.

Overstating the benefits or understating the risks of surgery can breach the Montgomery duty even when the operation is done competently. Patients must be given a fair picture including the option of not operating.

Claimant succeeded

Plan v El-Amir & Anor

[2020] EWHC 2902 (QB)·2020·Liability decided at trial

A 79-year-old with macular degeneration was persuaded to have an intraocular lens implant in her better eye without proper informed consent, then developed raised eye pressure that the surgeon left untreated for five weeks. Stacey J found the surgeon negligent both in consenting and in delaying laser treatment, causing total blindness in that eye.

Private eye surgeons must obtain genuinely informed consent and act promptly on post-operative complications. A delay that materially contributes to permanent damage is enough for liability even if some harm had already occurred.

Claimant succeeded£92,391

Thomas v Curley

[2013] EWCA Civ 117·2013·Appeal decision

Mrs Thomas's bile duct was injured during keyhole gallbladder removal and the surgeon also failed to arrange fluid and kidney monitoring when she was readmitted unwell. The trial judge found both failures negligent and awarded £92,391; the Court of Appeal dismissed the surgeon's appeal.

Bile duct injury during gallbladder surgery is not automatically negligent, but a court can find negligence where the anatomy was recognised and the injury still occurred, and separately for inadequate monitoring afterwards.

Claimant succeeded

Lesforis v Tolias

[2018] EWHC 1225 (QB)·2018·Liability decided at trial

Two days after spinal fusion surgery Mrs Lesforis suddenly lost movement in her feet; re-operation found a compressive blood clot. Martin Spencer J held it was negligent to give the blood-thinner Clexane routinely within about three hours of spinal surgery, which caused the haematoma, although the timing of the re-operation was not negligent.

Routine practices that fall outside the normal range at the time can be negligent even if the surgeon always did it that way. Post-operative anticoagulation after spinal surgery carries a recognised bleeding risk that must be weighed for each patient.

Claim failed

Tarrant v Monkhouse

[2025] EWHC 2576 (KB)·2025·Liability decided at trial

After a sleeve gastrectomy the claimant had trouble swallowing; the surgeon performed a gastroscopy and balloon dilatation, after which the sleeve leaked. The judge found no breach of duty in the post-operative care or the dilatation and dismissed the claim despite the very serious consequences.

A bad outcome after a recognised complication is not enough; the claimant must show the treatment decision fell outside what a responsible body of surgeons would do. Sympathy for the patient does not change the legal test.

Claim failed

Julia Tosh v Vivek Gupta

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

The claimant developed anal stenosis after a private haemorrhoidectomy and argued her haemorrhoids had been over-graded, non-surgical options were not discussed and the stenosis risk was not explained. The judge found the grading was correct, alternatives were discussed and the risk was disclosed on the consent form and in the information leaflet, so the claim was dismissed.

Documented consent, including a signed form and a written leaflet naming the specific complication, can be decisive in defeating a Montgomery consent claim.

Browse the whole case library →

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.

§ QUESTIONS

Common questions

Can I claim against a private hospital?

Yes, but the right defendant is often the consultant rather than the hospital. In Alexander the hospital was cleared and the doctor held liable; in Healey both were responsible.

I paid for the operation. Does that change the standard of care?

No. The legal test is the same as for NHS care. What changes is who defends the claim and whose insurer pays.

Was I properly consented for private surgery?

Thefaut and Plan both succeeded on consent in private practice. The surgeon must give a fair picture of benefits, risks and alternatives, including not operating.

A complication happened at a private hospital. Is that enough?

No. Tarrant failed because the leak was a recognised complication with no breach in the care. The same causation rules apply.

How long do I have?

Three years from the injury, or from when you first realised the care may have fallen short.

This guide is general information about the law in England and Wales, not legal advice about your case. ClaimGavel is run by Costart Projects Ltd on behalf of Tomlin & Partners, a specialist medical negligence firm regulated by the SRA. The free assessment on this page is an AI overview to show you roughly where you stand; a solicitor confirms the position in a free, no-obligation conversation.