PRINCIPLE STATEMENT

Since the patient's relationship with the practitioner is based on consensus, it follows that the choice of an adult patient with a sound mind to refuse informed consent to medical treatment, barring state intervention through judicial process, leaves the practitioner helpless to impose a treatment on the patient. That helplessness presents him with choices. He could terminate the contract, and, I would say, callously, force the patient out of his clinic or hospital; he could continue to give him refuge in his hospital and withdraw any form of treatment; he could do the best he could to postpone or ameliorate the consequences of the patient's choice. To a large extent the practitioner should be the judge of the choice that may be better in the circumstances. The choices become a question of personal attitude rather than one of professional ethics.

RATIO DECIDENDI (SOURCE)

Per Ayoola, JSC, in Medical and Dental Practitioners Disciplinary Tribunal v. Okonkwo (2001) NLC-2131999(SC) at p. 36; Paras C–E.
"Since the patient's relationship with the practitioner is based on consensus, it follows that the choice of an adult patient with a sound mind to refuse informed consent to medical treatment, barring state intervention through judicial process, leaves the practitioner helpless to impose a treatment on the patient. That helplessness presents him with choices. He could terminate the contract, and, I would say, callously, force the patient out of his clinic or hospital; he could continue to give him refuge in his hospital and withdraw any form of treatment; he could do the best he could to postpone or ameliorate the consequences of the patient's choice. To a large extent the practitioner should be the judge of the choice that may be better in the circumstances. The choices become a question of personal attitude rather than one of professional ethics."
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EXPLANATION / SCOPE

An adult patient with a sound mind has the right to refuse informed consent to medical treatment. Without state intervention (e.g., court order), the practitioner cannot impose treatment. The practitioner has choices: terminate the relationship, withdraw treatment, or ameliorate consequences. The choice becomes a matter of personal attitude, not professional ethics. The principle respects patient autonomy and bodily integrity. The practitioner cannot be disciplined for respecting a competent patient’s refusal. The patient’s decision binds the practitioner. The practitioner’s duty does not override patient consent. The principle applies to all medical treatment, including life-saving measures. The state may intervene only through judicial process with compelling justification. The practitioner’s ethical duty yields to patient autonomy.

CASES APPLYING THIS PRINCIPLE