Mid Yorkshire Teaching NHS Trust v SC & Anor

Mid Yorkshire Teaching NHS Trust v SC & Anor

SC lacks capacity to decide on the Caesarean section due to a disturbance in the functioning of her mind or brain, specifically mania with psychotic symptoms and delusional beliefs. The overwhelming medical evidence demonstrates that a planned Caesarean section is necessary to avoid significant risks to SC and her unborn child. Despite the serious interference with her autonomy, it is in SC’s best interests for the procedure to proceed as planned.

Parties
Applicant: Mid Yorkshire Teaching NHS Trust; First Respondent: SC; Second Respondent: South West Yorkshire Partnership NHS Foundation Trust
Jurisdiction
England and Wales
Judgment Date
28 November 2024
Procedural Posture
Mental Capacity Application (court of Protection) / Judgment on Urgent Application for Best Interests Declaration
Outcome
Application granted
Legal Topics
Best Interests Determination, Capacity to Consent to Medical Treatment, Caesarean Section Authorization, Mental Health Act Detention, Human Rights (autonomy and Article 8)
Mental Capacity Law Health Law Family Law Best Interests Determination Capacity to Consent to Medical Treatment Caesarean Section Authorization Mental Health Act Detention Human Rights (autonomy and Article 8)

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Parties

Mid Yorkshire Teaching NHS Trust

Applicant

SC

First Respondent

South West Yorkshire Partnership NHS Foundation Trust

Second Respondent

Procedural Posture

Mental Capacity Application (court of Protection) / Judgment on Urgent Application for Best Interests Declaration

Legal Issues

  1. 1 Does SC have capacity to decide whether to undergo a planned Caesarean section?
  2. 2 If not, is it in SC’s best interests for the Caesarean section to proceed against her wishes?

Ratio Decidendi

SC lacks capacity to decide on the Caesarean section due to a disturbance in the functioning of her mind or brain, specifically mania with psychotic symptoms and delusional beliefs. The overwhelming medical evidence demonstrates that a planned Caesarean section is necessary to avoid significant risks to SC and her unborn child. Despite the serious interference with her autonomy, it is in SC’s best interests for the procedure to proceed as planned.

Court Disposition

Application granted

Orders

  • Declaration that SC lacks capacity to decide on delivery by Caesarean section
  • Authorization for the applicant NHS Trust to proceed with a planned Caesarean section in SC’s best interests on or after 4 November 2024