What is the Bolam test?

A doctor is not negligent if they acted in line with a responsible body of medical opinion skilled in that field, even if others would have acted differently.

Who won Bolam v Friern Hospital?

The defendants (hospital/doctors) succeeded. The High Court held that their method matched a responsible body of medical opinion.

Does the Bolam test ignore patient warnings?

No. Bolam asks whether the professional practice followed is accepted by a responsible body. Later cases add safeguards on risk disclosure.

Does good practice need to be the majority view?

Not necessarily. It must be a responsible and logical body of opinion, not an irrational minority.

How to remember the rule quickly?

Think: ‘Doctor safe if with the group’—if care matches a responsible group of experts, negligence is not proven.

bolam-v-friern-hospital-management-committee-bolam-test

Bolam v Friern Hospital (1957) — Bolam Test

Medical Negligence • Professional Standard • Responsible Body • Easy-English Explainer

High Court (QBD) 1957 [1957] 1 WLR 582 Torts / Medical Negligence 6 min read

CASE_TITLE: Bolam v Friern Hospital (Bolam Test) PRIMARY_KEYWORDS: Bolam test, medical negligence, standard of care SECONDARY_KEYWORDS: responsible body, ECT, risk warnings, professional negligence PUBLISH_DATE: 31-10-2025 AUTHOR_NAME: Gulzar Hashmi LOCATION: India slug: bolam-v-friern-hospital-management-committee-bolam-test

Quick Summary

The Bolam test says a medical professional is not negligent if their actions match a responsible body of medical opinion. Even if other doctors disagree, following one responsible school of practice can be enough to avoid liability.

Issues

How do we judge a doctor’s care when experts themselves disagree?
Is a doctor negligent if they choose one accepted method over another?

Rules

Bolam test: If care aligns with a responsible body of medical opinion, the doctor is not negligent.
There can be more than one proper school of practice for the same treatment.

“Responsible” means credible, logical, and expert—not a careless minority view.

Facts (Timeline)

Patient & Therapy: Mr. Bolam, a psychiatric patient, underwent electro-convulsive therapy (ECT).

No Relaxants/Restraint: He was not given muscle relaxants and was not manually restrained.

No Risk Warning: He was not warned about fracture risk before the procedure.

Injury: During ECT he suffered fractures to both hips, pelvis, and femur.

Medical Split: Some experts avoided relaxants due to their risks; others preferred relaxants and manual control.

Claim: Bolam sued the hospital/doctors alleging negligence.

Chronological timeline of events in Bolam v Friern Hospital

Arguments

Appellant (Patient)

Failure to use relaxants/controls increased known risk of fractures.
No warning was given about material risks.
A careful doctor would have used safer measures or warned.

Respondents (Doctors/Hospital)

The chosen method was accepted by a responsible body of specialists.
Relaxants had their own risks; practice varies across reputable clinicians.
Following one responsible school should not be labeled negligent.

Judgment

Held for the defendants. The High Court ruled that the doctors did not breach their duty. Their method matched a responsible body of medical opinion, so negligence was not proved.

Ratio

Core idea: A professional meets the standard of care if their actions accord with a responsible body of skilled opinion—even if another responsible body would disagree.

Why It Matters

Sets the classic yardstick for professional negligence in medicine.
Accepts plurality of safe methods when expert opinion responsibly differs.
Guides courts on not substituting judicial views for medical judgment.

Key Takeaways

Responsible-body compliance defeats negligence.

There can be more than one safe practice.

Courts avoid second-guessing technical choices.

Warning duties later refined by later cases.

Mnemonic + 3-Step Hook

Mnemonic: “BRaVE” — Body (responsible), Reasoned, Variety accepted, Expert-led.

Find the Body: Is there a responsible group of experts backing the method?
Check Reasoning: Is the practice logical and defensible?
Accept Variety: Different safe methods can both pass Bolam.

IRAC Outline

Issue: How do we assess a doctor’s standard of care when expert opinions conflict?

Rule: Not negligent if actions align with a responsible body of medical opinion.

Application: Doctors chose a method accepted by a significant body that avoids relaxants; injuries alone do not prove negligence.

Conclusion: No breach—claim fails under the Bolam test.

Glossary

Bolam Test: Rule that shields a doctor who follows a responsible body of medical opinion.
Responsible Body: A credible, skilled group whose practice is logical and defensible.
ECT: Electro-convulsive therapy—a psychiatric procedure using controlled electric currents.