§ GUIDE · WHAT YOU HAVE TO PROVE

Why medical negligence claims fail,
and what the winners prove.

A bad outcome is not the same as negligence. Courts ask three questions, and a claim has to answer all of them. The judgments below are ones the claimant lost. Read together, they are the clearest guide there is to what a successful claim needs.

Questions the court asks

3

Failed claims in this guide

11

Standard applied

Of the time

Agreed damages if no breach

£0

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§ THE THREE QUESTIONS

Breach, causation, loss. Miss one and the claim fails.

Every clinical negligence claim in England and Wales has to prove three things. First, that the care fell below the standard of a reasonably competent clinician in that field: the Bolam test, with the court checking that the practice relied on stands up to logic (Bolitho). Second, that the failure caused the harm, or made a material contribution to it. Third, that the harm is something the law compensates.

Most failed claims fall at the first or second hurdle. The judgments below show how.

§ A WRONG DIAGNOSIS IS NOT ALWAYS NEGLIGENT

If a responsible body of specialists would have done the same, there is no breach.

Beatty v Lewisham and Greenwich [2023] EWHC 3163 (KB)

A vascular surgeon diagnosed vasculitis rather than an embolism and did not order a CT angiogram; the patient later needed a below-knee amputation. The judge found the diagnosis was supported by a responsible body of medical opinion and dismissed the claim.

Runciman v University Hospital Southampton [2024] EWHC 1800 (KB)

A rare cerebral venous thrombosis was treated as a stroke and the patient died. The court found the clinicians acted reasonably on what they saw, and that earlier correct treatment would probably not have saved her.

Graham v Dr Altaf [2023] EWHC 156 (KB)

A three-year-old was diagnosed with tonsillitis and turned out to have meningococcal meningitis. The court found no causative breach of duty: early symptoms genuinely resembled a common infection.

§ STANDARDS OF THE TIME

Care is judged by the guidance of the year it happened, not today's.

Taylor v Chesterfield Royal Hospital [2019] EWHC 1043 (QB)

A registrar used moderate downward traction to free a baby's shoulder in 1992 and caused a permanent brachial plexus injury. The judge found that traction of that kind was accepted practice in 1992, even though it is avoided now. Damages had been agreed at £1,150,000, and nothing was recovered.

LMN v Swansea Bay University Health Board [2025] EWHC 3402 (KB)

A 2003 delivery complicated by pre-eclampsia and an impacted fetal head. The plan of fetal blood sampling, attempted forceps and then caesarean met the standards of the day, so the claim failed.

PXE v University Hospitals Birmingham [2024] EWHC 2023 (KB)

The mother's history of kidney scarring was said to require consultant-led care and growth scans. The judge held that classifying the pregnancy as low risk was within acceptable practice in 2008.

§ WHAT THE EVIDENCE ACTUALLY SHOWS

The court looks at the scan, the notes and the messages, not the outcome.

Spellman v Portsmouth Hospitals [2024] EWHC 2011 (KB)

The claimant said a radiologist missed cauda equina compression on her MRI. Damages had been agreed at £300,000 if she won. The judge examined the scan and found no compression to be seen, so the report was accurate and the claim failed.

Hepworth v Dr Coates [2025] EWHC 1907 (KB)

A 27-year-old saw her GP with severe back and leg pain and needed cauda equina surgery four days later. The judge accepted that the GP asked the red-flag questions and the patient answered no. No breach of duty.

Tosh v Gupta [2025] EWHC 2025 (KB)

After a haemorrhoidectomy the claimant developed anal stenosis and said the risk was never explained. The consent form and the written leaflet named the complication. The claim was dismissed.

Guest v Nottingham University Hospitals [2026] EWHC 704 (KB)

A cardiac arrest during spinal surgery left the claimant with severe sight loss. He said a raised potassium reading was ignored; the judge found the reading was spurious and the arrest was caused by a pulmonary embolism.

§ CAUSATION

Even a proven error fails if it did not cause the harm.

In Saunders v Central Manchester University Hospitals [2018] EWHC 343 (QB), the claimant's whole colon had to be removed after surgery to reverse his ileostomy. He said the surgeon had damaged an artery. The judge was not satisfied the injury was caused by negligence rather than a naturally occurring clot, and the claim was dismissed.

The lesson runs through all of these cases: agreeing the value of a claim in advance, or suffering a devastating outcome, counts for nothing unless the court is persuaded that a specific decision fell below the standard of the time and that a better decision would have changed what happened.

§ 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. Losses are as instructive as wins.

Claim failed

Jacqueline Beatty v Lewisham and Greenwich NHS Trust

[2023] EWHC 3163 (KB)·2023·Liability decided at trial

Ms Beatty, in hospital with severe cellulitis, developed ischaemic toes; a vascular surgeon diagnosed vasculitis rather than an embolism and did not order a CT angiogram, and she later needed a below-knee amputation. The judge found the surgeon's diagnosis was supported by a responsible body of medical opinion and dismissed the claim.

A diagnosis that turns out to be wrong is not automatically negligent; if a responsible body of specialists would have reached the same view on the information available, the claim fails under the Bolam test.

Claim failed

David John Saunders v Central Manchester University Hospitals NHS Foundation Trust

[2018] EWHC 343 (QB)·2018·Liability decided at trial

Five days after surgery to reverse his ileostomy the 60-year-old claimant developed sepsis and his whole colon had to be removed because its blood supply had failed. He alleged the surgeon had damaged the marginal artery, but Yip J was not satisfied that the injury was caused by negligence rather than a naturally occurring clot.

A serious complication after bowel surgery is not itself proof of negligence; the claimant must show on the balance of probabilities that a surgical error, rather than an unavoidable event, caused the harm.

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.

Claim failed

Callum Joe Guest v Nottingham University Hospitals NHS Trust

[2026] EWHC 704 (KB)·2026·Liability decided at trial

During long spinal surgery for scoliosis and chest wall deformity the claimant deteriorated, arrested while being turned over, and was left with severe sight loss. He alleged the anaesthetist negligently failed to treat a raised potassium reading, but the judge found that reading was spurious and the arrest was caused by a pulmonary embolism, so the claim failed.

Even after a devastating complication a claim fails if the court finds the true cause was a non-negligent event, so proving the mechanism of injury is often the decisive issue.

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

Karen Spellman v Portsmouth Hospitals University NHS Trust

[2024] EWHC 2011 (KB)·2024·Liability decided at trial

Ms Spellman alleged a hospital radiologist missed cauda equina compression on an MRI scan taken the day after her fall, delaying diagnosis until private surgery six days later. Damages had been agreed at £300,000 if she won, but the judge found the scan showed only mild stenosis with no compression to be found, so the claim failed.

Parties sometimes agree the damages figure in advance and fight only liability, so a claimant who loses on breach of duty recovers nothing. Expert evidence on what the scan actually showed was decisive.

Claim failed

Rebeccah Taylor v Chesterfield Royal Hospital NHS Foundation Trust

[2019] EWHC 1043 (QB)·2019·Liability decided at trial

A 4.93kg baby's shoulder became stuck at delivery and the registrar used moderate downward traction to free her, causing a permanent brachial plexus injury. The judge found that traction of that kind was accepted practice in 1992, even though it is now avoided, so the claim failed.

Negligence is judged by the standards at the time of the birth, not today's guidance, which is decisive in many historic Erb's palsy claims. An agreed damages figure is worth nothing unless breach of duty is proved.

Claim failed

LMN (a protected party, by his mother and litigation friend PQR) v Swansea Bay University Health Board

[2025] EWHC 3402 (KB)·2025·Liability decided at trial

The claimant alleged the registrar at the Princess of Wales Hospital, Bridgend, delayed delivery after a pathological CTG in a labour complicated by pre-eclampsia and an impacted fetal head. The judge found the plan of fetal blood sampling, attempted forceps and then caesarean met the standards of the day and dismissed the claim.

A poor outcome after a difficult delivery is not enough; the claimant must show specific decisions fell below acceptable practice at the time and that earlier action would have avoided the injury. The material contribution argument does not help if no negligent cause of delay is proved.

Claim failed

PXE (by his mother and litigation friend DSD) v University Hospitals Birmingham NHS Foundation Trust

[2024] EWHC 2023 (KB)·2024·Liability decided at trial

The mother's recorded history of kidney scarring was said to require consultant-led care and serial growth scans, which were not arranged; the baby was born prematurely at Solihull Hospital with brain damage. The judge held that classifying the pregnancy as low risk was within acceptable practice in 2008, so there was no breach of duty.

Antenatal risk-assessment claims turn on whether the mother's history genuinely required extra monitoring under the guidance of the time. Hindsight that scans might have helped is not the legal test.

Claim failed

Runciman v University Hospital Southampton NHS Foundation Trust

[2024] EWHC 1800 (KB)·2024·Liability decided at trial

A widower claimed that doctors at Southampton General misdiagnosed his wife's rare cerebral venous thrombosis as a stroke, gave her clot-busting drugs and delayed the correct treatment, leading to her death. The judge found the clinicians acted reasonably on the presentation and that even earlier correct treatment would probably not have saved her.

A tragic outcome after a rare condition is missed does not by itself prove negligence; the question is whether a reasonable body of doctors would have acted the same way on the information available. Causation must be proved separately.

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.

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

Is a bad outcome enough to make a claim?

No. Medicine carries risk and things go wrong without anyone being at fault. A claim needs proof that the care fell below the standard of a reasonably competent clinician and that this caused harm you would otherwise have avoided.

What is the Bolam test?

The standard used to judge breach of duty in England and Wales. Care is not negligent if it accords with a practice accepted as proper by a responsible body of clinicians in that field, provided the practice stands up to logical scrutiny. Beatty v Lewisham and Greenwich is an example of a claim failing on it.

Why do courts judge care by the standards of the past?

Because the clinician can only be expected to follow the guidance that existed at the time. Taylor v Chesterfield Royal Hospital turned on what was accepted practice in 1992, not what midwives are taught today.

If we agree the damages, do I still have to prove negligence?

Yes. Parties sometimes agree what the claim is worth and fight only liability. In Spellman v Portsmouth Hospitals the agreed £300,000 was never paid because breach of duty was not proved.

What can I do to give my claim the best chance?

Get advice early, keep every letter, discharge summary and message, and write down dates and names while they are fresh. Contemporaneous records decided Hepworth v Dr Coates and Tosh v Gupta.

Does a failed claim cost the patient anything?

That depends on how the claim is funded. The free assessment on this page and the first conversation with Tomlin & Partners cost nothing, and the firm explains its fees before you decide anything.

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.