31 Sidaway (n27) per Lord Bridge at 898 – 900. In Sidaway, as noted earlier, Lord Bridge held that the duty to disclose was governed by the professional standard subject to the caveat that some risks were so ‘obviously necessary to the informed choice on the part of the of the patient’ that they must be disclosed. Lord Eassie however applied Sidaway and therefore the Bolam test and her appeal was dismissed. Whilst Lord Eassie also considered the approach of Lord Bridge in Sidaway, he considered that the relevant risk was not of shoulder dystocia occurring, but of the ‘much smaller risk of a grave adverse outcome’. 28 ibid per Lord Diplock at 892 – 894. Sidaway case is the starting point to this discussion which, in subsequent cases and by comparison of English law with North American and Australian jurisprudence, will ... disclosure but there was unease in Lord Bridge’s judgement.9 He also found the 32 ibid at 900 – 901. 29 Bolam v Friern Hospital Management Committee 1957 1 WLR 582. 50 He relied on the example of a 10% risk of stroke. Despite a meagre and somewhat confusing attempt by Lord Bridge (with whom Lord Keith agreed) to restrict the ambit of the Bolam test in respect of preoperative medical information, the legal standard of disclosure was still principally governed by the commonly accepted practice of the medical profession. The first is that it would fail to take into account the reality of the doctor patient relationship in many situations. Lord Bridge, in Sidaway, said that "The judge might in particular circumstances come to the conclusion that disclosure of a particular risk was so obviously necessary to an informed choice on the part of the patient that no reasonably prudent medical man would fail to make it. Again Sidaway compares well, with the Bolamite majority unanimous in its view that, when questions are asked by the patient they should be answered fully, and in this occasion Bolam is a useful tool rather than a hindrance. 30 ibid. - 20 - LORD BRIDGE OF HARWICHMy Lords, The facts giving rise to this appeal have been fullyrecounted by my noble and learned friend, Lord Scarman. He stated simply that The judgement goes a certain distance to reconcile the approaches of Lord Scarman, Lord Bridge and Lord Templeman in Sidaway. I have had the advantage of reading in draft the speech tobe delivered by my noble and learned friend, Lord Bridge ofHarwich. In Sidaway v Board of Governors of the Bethlehem. 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