In the case Samira Kohli vs. Dr. Prabha Manchanda and Ors. I (2008) CPJ 56 (SC), the Hon’ble Supreme Court stated: “32. iii: Consent given for a specific treatment procedure will not be valid for conducting some other treatment procedure.”

However, in the same judgment, the Hon’ble Court stated: “32. iv. There can also be a common consent for a particular surgical procedure and an additional or further procedure that may become necessary during the course of surgery.”