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REMEDIES FOR BREACH OF STATUTORY DUTY

decide. The ruling in Birch also demonstrates the gradual but continuing change in attitude of the judiciary towards autonomy. The House of Lords’ decision in Chester v. Afshar [2004] UKHL 41; [2005] 1 A.C. 134 was the first case in which positive moves were made to give greater weight to the duty of disclosure. There exists considerable academic debate as to whether or not the Lords actually did modify the rules of causation in Chester in order to attribute liability (J. Stapleton, ‘Occam’s Razor Reveals an Orthodox Basis for Chester v. Afshar’ (2006) 122 L.Q.R. 426). However, what is evident is that the perception of the Lords was that this was what they were doing so as to give teeth to the duty of disclosure and safeguard the patient’s right to selfdetermination. Birch is a further example of a pragmatic approach where a judge has been willing to consider what is fundamentally at stake and how, practically, the law can achieve one of its main aims, namely, the protection of autonomy.