§ GUIDE · EVIDENCE

It is decided on paper,
not on what you remember

Families usually think a claim turns on how serious the injury was. It does not. Reading 145 published judgments, the same things decide them over and over: what the clinician wrote down at the time, what the charts showed, whether a letter or result went missing, and which expert the judge preferred. Here is what that looks like in practice.

Judgments read

11

Decided on the notes

6 of 11

Library behind this

145 cases

What rarely decides it

How bad it was

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§ BEFORE YOU GO FURTHER

Before you ask for your records, these are the things worth knowing

  • Almost everything turns on the contemporaneous record: what was written at the time, not what anyone remembers afterwards.
  • That cuts both ways. A well-documented examination can defeat a claim, and a missing or contradicted record can win one.
  • An admission that care fell short is a starting point, not a result. Most of the losses in our library are cases where a failure was accepted.
  • Get the full set, not the discharge summary: nursing notes, observation and drug charts, imaging and its reports, and any correspondence.

None of this is a reason not to ask. It is a reason to ask early and ask for everything, because the record is the case.

§ 01

The notes usually beat memory

Doy v Gunn is the clearest example. A six-week-old baby was diagnosed with colic at an out-of-hours clinic and later developed meningitis with severe disability. Earlier referral would have prevented it, and the claim still failed, because the trial judge accepted the GP's contemporaneous note of how the baby looked over the mother's later recollection. The Court of Appeal upheld that.

Hepworth v Coates went the same way on cauda equina: the court looked closely at what safety-netting questions the GP actually asked and what the patient answered on the day, using the notes and the messages between them. In Canavan v Gaynor the GP conceded that hospital referral would have saved the claimant's leg, and still won, because his documented history and examination reasonably excluded infection.

This is the single most important thing to understand before you start. If you remember telling someone about a symptom and the note does not record it, that is a fight, and it is a fight the note usually wins.

§ 02

When the record is what wins it

The same principle helps claimants at least as often. In MJF v University Hospitals Birmingham the judge rejected the doctor's account of how a feeding tube had been fixed because the physical evidence contradicted it, and entered judgment for the claimant. In Alexander v HCA International the drug chart showed no preventive medication had been prescribed before an endoscopic procedure, and poor record-keeping counted heavily against the consultant, who was ordered to pay the agreed £550,000.

Absence of a record matters too. In Shaheen v Daish a chest X-ray was ordered on the computer but there was nothing to show the patient had been told to attend; the court held he would have gone if told, and did not blame him for not chasing a test he did not know about. In Oliver v Williams an urgent cancer referral was made, never mentioned to the patient, and lost by the hospital.

§ 03

Charts are evidence, not proof

Failes v Oxford University Hospitals is the warning here. After surgery to remove a spinal cord tumour, the nursing observation charts appeared to show the patient deteriorating, and the surgeon was not alerted; four days later she was permanently paralysed. The claim failed because the court accepted the clinicians' own examinations, which recorded improvement, over what the charts seemed to show.

Hakmi v East and North Hertfordshire makes the related point. The judge found the documentation poor and the claim still failed, because the missing treatment would probably not have changed the outcome. Bad paperwork is a strong start and not a case.

§ 04

The expert sets the standard, and judges choose between them

Whether care fell below standard is decided by independent experts in the same speciality, and the judge picks between them. In Dalton v Southend a woman with a breast lump was discharged without a biopsy after reassuring imaging, and the court accepted a responsible body of breast surgeons would have done the same. That single finding ended the claim.

Toth v Jarman adds a practical point about experts. The Court of Appeal held that an expert's undisclosed connection to the defendant's medical defence organisation did not by itself make the evidence inadmissible, but it is the kind of thing that should be disclosed. Expect your solicitor to spend real time and money choosing the right expert, because that choice often decides the case.

§ 05

What an admission does and does not do

Hospitals admit things more often than people expect, and it matters less than people expect. Across our library there are many judgments where a failure was admitted or found and the claim still failed, because the outcome would have been the same. That second question, whether it would have made a difference, is where most cases are lost.

An admission still has force on the facts. In MAN v St George's the Trust admitted negligence after a woman was sent home from A&E and lost her leg to a necrotising infection, then tried to dispute at trial how much pain she had reported. The court ruled that evidence inadmissible because the Trust had never pleaded that dispute. What a defendant admits, it is generally stuck with.

§ THE JUDGMENTS BEHIND THIS GUIDE

The eleven judgments behind this guide.

Every one a published decision of the courts of England and Wales, linked to its source. Drawn from a library of 145 verified judgments.

Claim failed

Doy v Gunn

[2013] EWCA Civ 547·2013·Appeal decision

A six-week-old premature baby was seen at an out-of-hours clinic, diagnosed with colic and not referred to hospital; he developed bacterial meningitis and was left severely disabled. The trial judge accepted the GP's contemporaneous note over the mother's recollection of symptoms and found no negligence, and the Court of Appeal upheld that decision.

Even where earlier hospital referral would have prevented the injury, the claim fails if the court accepts the GP's record of what the child looked like at the consultation. Contemporaneous clinical notes can outweigh a parent's later recollection.

Claim failed

Rebecca Hepworth v Dr Amanda Coates

[2025] EWHC 1907 (KB)·2025·Liability decided at trial

A 27-year-old flight attendant saw her GP with severe back and leg pain, having mentioned perianal numbness in a message two days earlier; she had emergency surgery for cauda equina syndrome four days after the consultation. The judge accepted that the GP asked the right red-flag questions and that the patient answered no, so there was no breach of duty.

In cauda equina cases the court looks closely at what safety-netting questions the GP actually asked and what the patient answered on the day. Contemporaneous notes and messages matter greatly for both sides.

Claim failed

Canavan v Gaynor

[2023] EWHC 1911 (KB)·2023·Liability decided at trial

A woman attended a GP drop-in clinic with groin pain after an injection had missed the vein; the GP diagnosed a haematoma and sent her away with painkillers, and days later she was admitted with necrotising fasciitis and her right leg was amputated at the hip. The judge found the GP's examination and diagnosis were ones a reasonable body of GPs would support, so the claim failed despite the defendant accepting that referral would have saved her leg.

Even where a devastating outcome and causation are accepted, a claim fails unless the clinician's decision fell outside what a responsible body of practitioners would have done. A properly documented history and examination that reasonably excluded infection was a complete defence.

Claimant succeeded

MJF v University Hospitals Birmingham NHS Foundation Trust

[2024] EWHC 3156 (KB)·2024·Liability decided at trial

A young woman with cerebral palsy had a PEG feeding tube inserted and was found unresponsive two days later with peritonitis and sepsis. The judge rejected the doctor's account of how the tube was fixed, found it was placed under too much tension, and entered judgment for the claimant.

Where a clinician's recollection is unreliable and contradicted by the physical evidence, the court can find a procedure was done negligently. Causation may still be limited where a pre-existing condition would have deteriorated anyway.

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

Shaheen & Anor v Dr Joanna Daish

[2025] EWHC 3056 (KB)·2025·Liability decided at trial

A 49-year-old man saw his GP with breathlessness and a persistent cough; the GP ordered a chest X-ray on the computer system but the judge found she never told him to go to the walk-in radiology department. The court held he would have attended if told and was not himself at fault.

Ordering a test is not enough; the patient must be told clearly what to do. Courts are slow to blame patients for not chasing a test they did not know had been requested.

Claimant succeeded£7,500

Oliver v Williams

[2013] EWHC 600 (QB)·2013·Liability and damages decided at trial

A woman with months of bloating and bowel symptoms was urgently referred by her GP, but the judge found he never told her and the hospital lost the letter, so nothing happened until she was diagnosed with advanced ovarian cancer seven months later. The GP was liable for the delay but only £7,500 was awarded because the delay was not shown to have shortened her life.

A GP must tell the patient an urgent referral has been made so it can be chased. Damages for delayed cancer diagnosis are limited to what the delay actually caused, which may be modest.

Claim failed

Failes v Oxford University Hospitals NHS Trust

[2020] EWHC 3333 (QB)·2020·Liability decided at trial

After removal of a spinal cord tumour, nursing charts appeared to show neurological deterioration two days post-op, but the surgeon was not alerted; four days later the patient suffered sudden permanent paralysis. The court accepted the clinicians' assessments that there was no real deterioration until the final day, so earlier escalation would not have changed the outcome.

Nursing observation charts alone may not prove deterioration if contemporaneous clinical examinations showed improvement. Even a failure to escalate must be shown to have changed the outcome.

Claim failed

Hakmi v East & North Hertfordshire NHS Trust & Anor

[2025] EWHC 2597 (KB)·2025·Liability decided at trial

An orthopaedic surgeon had a second stroke and the on-call stroke consultant, assessing by telephone because the video link was broken, decided against clot-busting treatment. The judge found documentation was poor but that thrombolysis would probably not have changed the outcome, and rejected the defendants' allegation that the claimant had faked his test results.

Poor record-keeping and a remote consultation do not win a case on their own; the claimant must show the missed treatment would have made a real difference. A defence of dishonesty needs solid evidence and failed here.

Claim failed

Dalton v Southend University Hospital NHS Foundation Trust

[2019] EWHC 832 (QB)·2019·Liability decided at trial

A 38-year-old woman with a hard breast lump had a mammogram and ultrasound that looked benign and was discharged without a biopsy; cancer was found in 2013. Yip J accepted that a responsible body of breast surgeons would not have biopsied on those findings.

Triple assessment does not always require a biopsy where imaging is reassuring. A later cancer diagnosis does not by itself prove the earlier clinic decision was negligent.

Mixed outcome

MAN v St George's University Hospital NHS Foundation Trust

[2024] EWHC 1304 (KB)·2024·Liability decided at trial

A woman went to A&E with extreme lower-leg pain and was sent home by a nurse practitioner instead of being seen by a senior doctor or referred to surgeons; she developed a necrotising soft tissue infection and lost her leg. The Trust admitted negligence but tried to rely on the nurse's evidence disputing how much pain she reported; the Master ruled that evidence inadmissible because the defence had never properly pleaded that dispute.

An NHS trust cannot admit negligence and then quietly contest the facts at trial without pleading them. Severe, out-of-proportion pain in a limb is a recognised warning sign of necrotising infection that calls for senior review.

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

What if the notes are wrong about what I said?

It is a real fight and the note usually wins, as Doy v Gunn shows. It is not hopeless: anything else written at the time helps, such as text messages, an online consultation form, a 111 record, or a note made by a relative that day.

Which records should I ask for?

Ask for the complete set, not a summary. That means nursing notes, observation and drug charts, test results with their reports, imaging and the radiologist's report, theatre and anaesthetic records, ambulance and A&E records, and letters between clinicians.

The hospital has admitted it got something wrong. Have I won?

No. Many of the losses in our library are cases where a failure was admitted or found, and the claim failed because the outcome would have been the same. The admission matters, but the question is what it changed.

Does bad record-keeping mean I have a claim?

It helps and it is not enough on its own. In Hakmi the judge found the documentation poor and still dismissed the claim. In Alexander poor drug-chart records counted heavily against the doctor, alongside evidence the drug was never given.

Why does my solicitor need an expert?

Because whether care fell below standard is a question for an independent specialist, not for the solicitor or the judge alone. In Dalton the whole claim turned on expert evidence that a responsible body of surgeons would have acted the same way.

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.