What is the current state of the law on causation in medical malpractice cases?

I agree with counsel for the defendant that the “robust and pragmatic” approach to causation enunciated in Snell v. Farrell, supra does not go so far as to shift the onus of disproving causation on the defendant, even when the very act or omission complained of leaves a plaintiff in the position of being unable to affirmatively establish causation. However, the case law does leave it open for the courts to infer causation on the basis of common sense, without the necessity of strict scientific proof.