Does consent to the use of forceps have to be considered in medical malpractice cases?

In Anderson-Redick v. Graham, 2000 ABQB 36, 258 A.R. 42, a case involving a traumatic forceps delivery, consent to the use of forceps was in issue. In determining that the defendant physician had failed in his obligation to properly advise the plaintiff, Paperny J. stated:

Individuals have the right to make their own health care decisions. In order to exercise this right in a meaningful way, a patient needs sufficient information to make an informed choice about medical treatment. Thus, except in limited circumstances, doctors are under a legal obligation to provide a patient with material information relating to a proposed treatment or procedure: Hopp v. Lepp, supra. This obligation has been called the ‘doctrine of informed consent’ or, in some cases, the ‘duty of disclosure’.