In failure-to-warn medical negligence cases, evidence of a breach of the duty to warn combined with the materialisation of the risks about which the patient was not warned is sufficient to establish a prima facie case of causation, capable of acceptance in the absence of a more plausible contrary inference. The evidentiary burden then shifts to the defendant to point to evidence suggesting no causal connection exists. The duty of disclosure extends not only to risks of the procedure but also to the necessity for the procedure and risks of not proceeding.
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