Scope of Duty and Causation: Chester v Afshar revisited
JUNE 2019
Contents
Programme
Slides
Hypothetical Case Study
Key Cases
Speakers
UK Human Rights Blog
Mediation Services
Members
Programme
Discussion of the Case Study Chaired by Clodagh Bradley QC
Updates on the law Dominic Ruck Keene Jonathan Metzer
Speakers for the Claimant: Robert Kellar QC, Isabel McArdle & Dominic Ruck Keene
Speakers for the Defendant: Sarabjit Singh QC, Pritesh Rathod & Jonathan Metzer
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Slide 1
Scope of Duty and Causation: Chester v Afshar revisited
Follow @1CrownOfficeRow, @1corQMLR visit our UK Human Rights Blog and listen to Law Pod UK for the latest legal updates
Slide 2
Chester v Afshar [2004] UKHL 41
Jonathan Metzer
What does it actually say?
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Slide 3
Background
C suffered repeated episodes of lower back pain.
She was referred for surgery to a consultant neurosurgeon, who was experienced in disc surgery.
She reluctantly underwent the surgery three days later.
The surgery led C to develop cauda equina syndrome, but it was found that the surgery was not performed negligently.
However, before the surgery the neurosurgeon had not warned C that there was a 1-2% risk of this complication arising.
Slide 4
The failure to warn
The failure to warn C of this risk was a breach of duty.
As to causation, the Judge found that if duly warned, C would not have undergone surgery three days after her first consultation with D, but instead would have had more discussions and explored other options.
However, the Judge did not find (and was not invited to find) that she would probably not have undergone the surgery.
Furthermore, it was not found that there was any way of reducing the risk inherent in surgery so that it would have been lower if the surgery had taken place on another day.
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Slide 5
What was the issue of law? (take 1)
Lord Hope (who found for C):
The question of law which arises from these findings is whether it was sufficient for Miss Chester to prove that, if properly warned, she would not have consented to the operation which was in fact performed and which resulted in the injury, or whether it was necessary for her to prove also that she would never have had that operation. The issue is essentially one of causation. [40]
Slide 6
What was the issue of law? (take 2)
Lord Hoffmann (dissenting):
The claimant argued that as a matter of law it was
sufficient that she would not have had the operation at
that time or by that surgeon, even though the evidence was
that the risk could have been precisely the same if she had
it at another time or by another surgeon. [28]
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Slide 7
The result
By a 3-2 majority, C succeeded.
Lords Steyn, Hope and Walker found for C.
Lords Hoffmann and Bingham dissented in favour of D.
Slide 8
The reasoning of the majority
Lord Hope:
The function of the law is to protect the patient's right to choose, which will not be protected if an appropriate remedy cannot be given where a patient is not informed of the very risk that occurs as a result of the surgery [56].
There was no doubt that in this case the injury which C sustained was within the scope of D’s duty to warn [62].
The issue of causation cannot be separated from an important issue of policy, regarding whether, in the unusual circumstances of this case, justice requires the normal approach to causation to be modified [85].
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Slide 9
The reasoning of the majority
Lord Hope (continued):
To leave the patient who would find the decision difficult without a remedy, as the normal approach to causation would indicate, would render the duty useless in the cases where it may be needed most … The function of the law is to enable rights to be vindicated and to provide remedies when duties have been breached. Unless this is done the duty is a hollow one, stripped of all practical force and devoid of all content ... On policy grounds therefore I would hold that the test of causation is satisfied in this case. [87]
Lords Steyn and Walker reasoned their conclusions in similar terms (see [24] and [101]).
Slide 10
So, to draw it together…
A clinician who fails to warn a patient of a risk of injury inherent in surgery may be liable when that risk eventuates, even if:
The risk was not increased by the failure to warn; and
The patient had not shown that she would never have had the operation had she been properly warned.
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Slide 11
The question left unanswered
Lord Steyn stated at [24] that this case involved “a narrow and modest departure from traditional causation principles”?
But the majority did not go into detail about when a claimant will or won’t satisfy this new principle. Where is its limit?
Slide 12
Cases post Chester v Afshar [2004] UKHL 41
Dominic Ruck Keene
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Slide 13
CASES POST CHESTER Sheer number of cases which have considered Chester and issues of causation/ scope of duty • 3 Court of Appeal decisions in last year alone
Key Court of Appeal cases • Correia v University Hospital of North Staffordshire NHS Trust [2017] EWCA Civ 356 • Shaw v Kovac [2017] EWCA Civ 1028 • Duce v Worcestershire Acute Hospitals NHS Trust [2018] EWCA Civ 1307 • Khan v Meadows [2019] EWCA Civ 152 • Diamond v Royal Devon & Exeter NHS Foundation Trust [2019] EWCA Civ 585
Also • South Australian Asset Management Corpn v York Montague Ltd [1997] AC 191 (“SAAMCO”). • Silence in Montgomery as not considered
Slide 14
THEMES FROM THE CASES POST CHESTER:
(Re-) Interpretation of Chester
Avoiding Chester
Confining Chester
Criticising Chester
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Slide 15
THEMES FROM THE CASES POST CHESTER: (RE-) INTERPRETATION OF THE RATIO OF CHESTER Shaw – decision on causation
Correia • Negligent failure to warn of a particular risk from an operation and the injury is intimately connected to the duty to warn, then injury caused by the breach of the duty to warn.
Duce • An ineffective ‘but for’ cause was sufficient cause in the circumstances. • Still have to prove operation would not have taken place when it did
Slide 16
THEMES FROM THE CASES: AVOIDING CHESTER
Crossman v St George’s Healthcare NHS Trust[2016] EWHC 2878 – “Baking the cake” on a different occasion, but still succeeded on ‘conventional’ causation
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Slide 17
THEMES FROM THE CASES: CONFINING CHESTER
No new duty • Shaw • Duce • Diamond
Re scope of duty not causation • Pomphrey
Requirement to plead • Correia
To consent • SAAMCO, sufficient connection and the mountaineer’s knee • Khan • Pomphrey v Secretary of State for Health [2019] 4 WLUK 483
To its facts • Correia – negligent failure within an operation did not vitiate informed consent • Diamond – no factual connection • Barry v Cardiff and Vale University LHB [2019] Med LR 191]
Slide 18
THEMES FROM THE CASES: CRITICISMS OF CHESTER
Meiklejohn v St George’s Healthcare NHS Trust [2014] EWCA Civ 120
Duce
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Slide 19
ANY HOPE FOR CHESTER?
Mills v Oxford [2019] EWHC 936 - The risk that happened was the risk that should have been warned about.
Slide 20
SUMMARY Conventional But For • Would never have consented to procedure • Damage has still to be related to risk for which should have been consented
Chester • Would have been delay • On later date on balance of probabilities damage would not occur • Damage must be within scope • Has to be explicitly pleaded
No separate head of loss for violation of personal autonomy
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Hypothetical Case Study
Kirsty is a 20 year old pianist, who has been tipped to be a future star of the classical scene. She is scheduled to appear in a prestigious concert in Vienna in July 2019, where she will have the opportunity to demonstrate her talent to the great and the good of the classical music world, and where she hopes to pick up a recording contract or further concert work.
In February 2019 she attends an appointment with Dr Smith, an Orthopaedic Surgeon at Temple NHS Foundation Trust. She has been experiencing some pain in her left hand which does not affect her ability to play piano but has been worrying her. Dr Smith diagnoses Symphony Syndrome, a rare autoimmune disorder in which benign growths build up in the joints of the hands and feet.
Dr Smith explains three options to her:
She can choose monitoring only, and may require treatment in a few years; She can have physiotherapy with may slow down the development of the growths; She can undergo surgery to her hand to reduce the growths.
Scenario 1
Dr Smith questions Kirsty about her lifestyle, and after she discloses that she is a smoker, he advises against surgery. He does not explain to her why smoking makes surgery a less attractive option, but clinical trials have shown that 2% of smokers suffer re-growth at ten times the rate of non-smokers following surgery. Kirsty reluctantly agrees to physiotherapy.
When Kirsty attends the clinic again in March for what she expects to be a physiotherapy appointment, owing to a mix up in the appointments system, she is instead seen by Dr Jones, another Orthopaedic Surgeon. She re-explains the three treatment options with Kirsty, but does not explore Kirsty’s lifestyle. Kirsty says that she is concerned about the growths affecting her performance in July, and that ideally she would like them to be surgically removed.
Dr Jones lists Kirsty for surgery. Kirsty keeps quiet about her smoking habit, not wanting to cause herself to be removed from the surgical waiting list and assuming that there is no serious risk posed by smoking as Dr Jones has not mentioned it and she is a highly renowned Surgeon.
Kirsty undergoes surgery in April 2019. Initially all appears well, but when she attends an appointment in early June, it is apparent she is suffering from the rapid regrowth which smokers are at risk of. This causes her to miss the July concert, and be unsuitable for future surgical treatment. Her career is over.
Question: has there been an actionable breach within the scope of the duty to warn?
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Scenario 2
Dr Smith questions Kirsty about her lifestyle, and she discloses that she is a smoker. He nevertheless advises that surgery may be suitable for her, and he does not explain to her that clinical trials have shown that 2% of smokers suffer re-growth at ten times the rate of non-smokers following surgery. Kirsty opts for surgery which occurs in April 2019.
When she attends an appointment in early June, it is apparent she is suffering from the very rapid re-growth to which smokers are prone.
Medical expert evidence indicates that her injury was not something which she had any predisposition to suffer, all smokers face this risk. Had Kirsty’s surgery taken place on a different day, she would only have faced a 2% risk.
Kirsty’s evidence is that, had she been warned of the risk, she may still have undergone surgery, but would have waited until after the concert in Vienna because she would then have been able to relax enough to give up smoking.
However, her Facebook profile reveals she is an ardent supporter of smokers’ rights, believing that smoking is a force for good and proudly proclaiming that she is “no quitter”. Her hobbies include a number of activities with a high risk of hand injury, such as goalkeeping on a football team and parkour.
Question: assuming Dr Smith has breached his duty of care in the consent process, can Kirsty rely on Chester causation?
Scenario 3
Dr Smith questions Kirsty about her lifestyle, and she discloses that she is a smoker. He nevertheless advises that surgery may be suitable for her, and he does not explain to her that clinical trials have shown that 2% of smokers suffer re-growth at ten times the rate of non-smokers following surgery. Kirsty opts for surgery which occurs in April 2019.
When she attends an appointment in early June, it is apparent she is suffering from a nerve injury which she was warned of and which occurred non-negligently during surgery.
Kirsty is furious when she learns that Dr Smith failed to warn her of the risk re-growth faced by smokers. She would never have consented to surgery if she had been warned, and is now left with a nerve injury. She feels violated, and stops attending any conventional medical appointments which now leave her in tears. She can only face treatment by alternative medicine practitioners.
Question: does Kirsty have a claim within the Chester principles?
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List of Key Cases
Pomphrey v Secretary of State for Health [2019] 4 WLUK 483 Barry v Cardiff & Vale University Local Health Board [2019] Med LR 191 Diamond v Royal Devon and Exeter NHS Foundation Trust [2019] EWCA Civ 585 Khan v Meadows [2019] 4 WLR 3 Duce v Worcester [2018] EWCA Civ 1307 Correia v University Hospital of North Staffordshire NHS Trust [2017] EWCA Civ 356 Shaw v Kovac [2017] 1 WLR 4773 Crossman v St George’s Healthcare NHS Trust [2016] EWHC 2878 (QB) Montgomery v Lanarkshire Health Board [2015] AC 1430 Chester v Afshar [2005] 1 AC 134
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CHAIR Clodagh Bradley QC
Year of call: 1996 Year of silk: 2016
Clodagh Bradley QC @ClodaghBradley
Clodagh Bradley QC specialises in healthcare regulatory law, clinical negligence and inquests with a medical or psychiatric element to them, including in custodial settings.
Her clinical negligence practice, on behalf of Claimants and Defendants, has included a variety of obstetric claims, surgical cases and missed diagnoses, resulting in catastrophic life- changing or fatal injuries, spanning brain or spinal injuries, limb loss and sight loss. She has dealt with a broad range of disciplinary cases predominantly on behalf of doctors before the Medical Practitioners Tribunal Service (previously GMC), and also cases brought by the General Dental Council (GDC), the General Osteopathic Council (GOsC), the General Optical Council (GOC) and the Nursing and Midwifery Council (NMC).
Clodagh has successfully challenged regulatory decisions in the Administrative Court. In inquests Clodagh has appeared on behalf of families, doctors, NHS Trusts, the police and the prison service as interested persons. Clodagh also undertakes work in the Court of Protection, dealing with matters relating to capacity, treatment decisions and the best interests of protected persons.
Qualifications: Magdalene College, Cambridge University, MA (Law) (1992-1995)
Awards: Middle Temple Astbury Major Scholar (1995-1996)
Middle Temple Harmsworth Major Entrance Exhibitioner (1995–1996)
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Directories: Clodagh has been recommended for many years by legal directories.
"A brilliant litigator. She is excellent on her feet and her paperwork is excellent. She is a real all-rounder and a robust negotiator." "Very bright and easy to deal with." (Chambers & Partners UK, 2019)
‘She has extraordinary capacity to absorb detail.’ ‘Fiercely bright, asks the right questions and is a tenacious and fearless advocate.’ ‘A highly effective advocate who never fails to impress.’ (Legal 500 2018)
“"Her attention to detail is exceptional and she is very user-friendly." "Extremely thorough and excellent with clients." (Chambers & Partners UK, 2018)
“Supremely confident and unrelenting." (Legal 500 2016)
"A first-class barrister who fights to the end and provides sound advice." (Chambers & Partners UK 2017)
“A reassuring presence in conference and a real fighter in the courtroom.” (Legal 500 2016)
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Sarabjit Singh QC
Year of call: 2001 Year of silk: 2018
Sarabjit Singh QC has long been recognised as a leading and versatile practitioner in various areas of law, with a growing emphasis on clinical negligence. He has a thriving advisory and court practice in this area and regularly acts for claimants, doctors and hospitals in cases involving complex medical evidence and profound and high-value injuries.
His work spans all areas of clinical negligence, such as delayed diagnosis of cancer and birth injury cases and cases raising more unusual medical issues, and his careful and high-quality pleadings and advocacy and tactful manner with clients invariably help secure excellent settlements and trial outcomes. He is known for his calm, cool and persuasive manner in court, especially when in highly pressurised situations, as the quotes below from his solicitors in the directories demonstrate.
Appointments: Attorney General’s A Panel of Junior Counsel to the Crown (2014- 2018) Attorney General’s B Panel of Junior Counsel to the Crown (2009- 2014) Attorney General’s C Panel of Junior Counsel to the Crown (2006- 2009)
Qualifications: MA (Oxon) in Jurisprudence
Publications: Contributor to AVMA newsletter, April 2019 Regular contributor of human rights articles, e.g. in the Judicial Review periodical.
Directories: Recommended as leading junior, and now a leading silk by Chambers & Partners.
"When handling our case, he remained incredibly cool under heavy fire from Supreme Court Judges." (Chambers & Partners 2019)
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“He remains cool and cheerful under intense judicial scrutiny, which is impressive to see.” “He prepares well and is very persuasive.” (Chambers & Partners 2018)
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Robert Kellar QC
Year of call: 1999 Year of silk: 2019
Robert has a broad civil, regulatory and public law practice which encompasses: clinical negligence, personal injury, professional discipline, judicial review/human rights, healthcare inquests and employment law.
In clinical negligence he is instructed by both Claimants and Defendants and has considerable experience in complex, multi-party and high value claims. He deals with all types of case including claims involving brain injury, spinal injury, vascular injury and missed cancer diagnoses. He is regularly instructed by Claimant and Defendants, including by Government Departments, in all types of personal injury claim. He was recently instructed as junior counsel, before taking silk, for the Claimants in the Paterson Group ligation.
He is highly recommended as a leading junior, now new silk, in the Legal 500 and Chambers & Partners.
Appointments: Junior Counsel to the Crown (A Panel) Panel of External Advisers to the Legal Services Board
Qualifications: LLM (Cantab) (First Class) – Queens College, Cambridge BA (Oxon) – Magdalen College, Oxford Academic Awards: Scholar of Queens' College, Cambridge; Scholar of Magdalen College, Oxford; Winner of Lee Essay Prize, Gray's Inn Directories:
"He's brilliant at every stage of a case." (Chambers & Partners 2019) ‘Very strong court advocate and a good strategic thinker.’ ‘Able to take on the most complex cases and can turn his hand to any aspect of public law.’ (Legal 500 2018)
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"Detailed and gives good practical advice. He was clear in advising clients while also being sensitive given the nature of the cases." "Calm and can make what might seem complicated simple." (Chambers and Partners 2018)
‘An exceptional talent.’ He is very approachable and gives excellent practical advice.’ ‘Always very thorough and detailed, and very approachable too.’ (Legal 500 2017)
"I find him very easy to deal with, very pragmatic and a good communicator. He always turns things around on time." (Chambers and Partners 2017)
"Extremely persuasive, charming and affable." (Legal 500 2016)
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Pritesh Rathod
Year of call: 2006
Pritesh Rathod is a sought after barrister who specializes in the fields of clinical negligence and personal injury. He regularly appears in the High Court and County Courts in a wide range of hearings, with a particular strength in trials and appeals. He represents both claimants and defendants.
His main area of practice is clinical negligence. His experience ranges from low value claims to multi-million pound claims and across the full range of medical specialisms. He has a significant amount of courtroom experience, appearing in applications, trials and appeals. He has successfully appeared in the Court of Appeal, having obtained a strike out in a case where it was alleged that the Claimant had received full compensation for her claim in previous proceedings. He also successfully appeared in an appeal relating to the use of employment experts in a brain injury claim. Pritesh has a special interest in quantum issues and is particularly proficient at drafting schedules and counter-schedules. He also has an interest in fatal accident claims.
Inquests also feature heavily in his practice, where he acts for families, NHS Trusts and individual doctors. Pritesh has experience in professional discipline cases and is keen to maintain a broad practice, he accepts instructions across a wide spectrum of common law areas.
Appointments: Registered Pupil Supervisor (2014 – present) Bar Council Social Mobility Committee Member (2012-2015) Secretary to South Eastern Circuit Minorities Committee (2009-2013) South Eastern Circuit Committee Member (2009-2013) Bar Council Training for the Bar Committee Member (2011-2012) Clerk to the Bar Disciplinary Tribunals (2009-2012) South Eastern Circuit Law School Liaison Officer (2009-2012)
Memberships: PIBA PNBA
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Qualifications: BPP Law School, BVC (Very Competent), (2006) King’s College London, LLB Hons (First Class), (2005)
Awards: Benefactors Scholarship (2005) Blackstone Entrance Exhibition (2005) Pump Court Tax Chambers Prize in Tax Law, King’s College, London (2005) Graveson Prize in Conflict of Laws, King’s College, London (2005)
Directories:
"His advocacy is something that is strongly in his favour." (Chambers & Partners 2018)
"Very bright and easy to work with." "Reliable, thorough and good on his feet." (Chambers & Partners 2017)
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Isabel McArdle
Year of call: 2008
Isabel McArdle @IsabelMcArdle
Isabel has extensive experience in healthcare law (including clinical negligence, cross-over public law matters, personal injury and inquests), public law (including human rights and public inquiries) and indirect tax.
She acts for Claimants and Defendants and was appointed to the Attorney General’s C Panel in 2014. Isabel’s clinical negligence and personal injury experience is wide ranging and includes birth injuries, wrongful birth, surgical complications, and orthopaedic injuries. She has particular experience in human rights claims arising in the healthcare setting.
Her inquest experience has had an emphasis on surgical problems and general practice diagnosis and referral.
Memberships: CALBA PIBA RBA VAT Practitioners Group
Qualifications: BA (Hons) in Jurisprudence, Brasenose College, University of Oxford (2007)
Awards: Lincoln’s Inn Lord Denning Scholarship (2007) Lincoln’s Inn Hardwicke Scholarship (2007)
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Dominic Ruck Keene
Year of call: 2012
Dominic Ruck-Keene
Dominic Ruck Keene has developed a varied practice in all the core areas of Chambers’ work, in particular inquests, public law and human rights, and clinical negligence. He also has a growing practice in the specialist areas of child abuse compensation, cyber and data protection, as well as employment and equality.
As a member of the Attorney General’s C Panel, he is instructed by a number of different Government departments in cases involving a wide spectrum of different areas of law.
Dominic accepts direct instruction from lay clients across a range of practice areas, with a particular interest in representing families at inquests.
Within clinical negligence and personal injury, Dominic has considerable experience of acting in clinical negligence claims for both claimants and defendants: drafting the full range of pleadings, advising on merits, quantum and settlement; successfully representing parties at RTMs and at mediation; as well as appearing in case management hearings, application hearings, and at trial in both the County and High Courts. This includes representing hundreds of claimants against Mr Ian Paterson.
Appointments: Attorney General’s C Panel of Counsel
Memberships: PIBA PNBA ALBA ELF
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Qualifications: Advanced International Advocacy Course, Keble College, Oxford (2016) ADR Group Accredited Mediator (2012) Bar Vocational Course, Very Competent – BPP, London (2012) MA War in the Modern World, Merit – King’s College London (2011) Graduate Diploma in Law, Distinction – City University (2005) MA (Oxon) Modern History First Class – St Peter’s College, Oxford (2004)
Awards: Lord Denning Scholarship - Lincoln’s Inn (2011) Lord Haldane Scholarship - Lincoln’s Inn (2005) Smith Prize for History and College Scholar - St Peter’s College (2002) British Army University Bursar (2001) British Army Sixth Form Scholar (1998) Eton College Oppidan Scholarship (1995)
Publications: ‘Big Brother Watch & Others v UK‘ Counsel Magazine, November 2018. Dominic is a regular contributor to the UK Human Rights Blog.
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Jonathan Metzer
Year of call: 2016
@JonathanMetzer
Jonathan Metzer is developing a broad practice across all areas of chambers’ work, with particular expertise in public and human rights law, asylum and immigration, clinical negligence and inquests. He appears regularly in the Immigration Tribunals, the County Court and the Coroner’s Court, and has also undertaken hearings in the Administrative Court.
He accepts instruction from lay clients, with particular interest in immigration, public law, inquests and civil matters.
Before coming to the Bar, Jonathan undertook voluntary work at The Death Penalty Project, Simons, Muirhead & Burton LLP. He also worked on a pro bono basis for the School Exclusion Project, acting as lay legal representative for the parents of excluded pupils at hearings in front of school governors and independent review panels.
Jonathan is also commissioning editor for the UK Human Rights Blog and appears on Law Pod UK.
Qualifications: BPTC (Very Competent), City University, London (2015-2016) GDL (Commendation), City University, London (2014-2015) BA Hons in Classics (Double First Class), Worcester College, Oxford (2010-2014)
Awards: Inner Temple Pegasus Award (2019) Lord Denning Scholar for the Bar Professional Training Course, Lincoln’s Inn (2015) Hardwicke Entrance Award for Membership of the Inn, Lincoln’s Inn (2015) Lord Bowen Scholar for the Graduate Diploma in Law, Lincoln’s Inn (2014) Graduate Diploma in Law Moot, Runner-up, City University, London (2014)
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MEMBERS OF CHAMBERS
QCs
Richard Booth QC 1993 QC 2013 David Evans QC 1988 QC 2012 Robert Seabrook QC 1964 QC 1983 Marina Wheeler QC 1987 QC 2016 Stephen Miller QC 1971 QC 1990 Henry Witcomb QC 1989 QC 2016 Philip Havers QC 1974 QC 1995 Owain Thomas QC 1995 QC 2016 Elizabeth-Anne Gumbel QC 1974 QC 1999 Jeremy Hyam QC 1995 QC 2016 Paul Rees QC 1980 QC 2000 Clodagh Bradley QC 1996 QC 2016 Margaret Bowron QC 1978 QC 2001 Peter Skelton QC 1997 QC 2016 David Balcombe QC 1980 QC 2002 Oliver Sanders QC 1995 QC 2017 David Hart QC 1982 QC 2003 Shaheen Rahman QC 1996 QC 2017 Martin Forde QC 1984 QC 2006 Sarah Lambert QC 1994 QC 2018 William Edis QC 1985 QC 2008 Sarabijt Singh QC 2001 QC 2018 Neil Sheldon QC 1998 QC 2019 Angus McCullough QC 1990 QC 2010 Robert Kellar QC 1999 QC 2019 John Whitting QC 1991 QC 2011
Juniors
John Gimlette 1986 Isabel McArdle 2008 Andrew Kennedy 1989 Matthew Hill 2009 Martin Downs 1990 Alasdair Henderson 2009 Giles Colin 1994 Claire McGregor 2009 Sydney Chawatama 1994 Matthew Flinn 2010 Justin Levinson 1994 Natasha Barnes 2010 Richard Smith 1999 Paul Reynolds 2010 Christopher Mellor 1999 Lois Williams 2012 Matthew Barnes 2000 Jim Duffy 2012 Iain O’Donnell 2000 Dominic Ruck Keene 2012 David Manknell 2001 Jessica Elliott 2013 Suzanne Lambert 2002 Hannah Noyce 2013 Judith Rogerson 2003 Michael Deacon 2014 Amy Mannion 2003 Rhoderick Chalmers 2014 Richard Mumford 2004 Emma-Louise Fenelon 2015 Rachel Marcus 2005 Gideon Barth 2015 Leanne Woods 2005 Jo Moore 2015 Pritesh Rathod 2006 Jonathan Metzer 2016 Caroline Cross 2006 Charlotte Gilmartin 2015 Matthew Donmall 2006 Rajkiran Barhey 2017 Michael Spencer 2017 Michael Paulin 2007 Amelia Walker 2007
Chambers of Richard Booth QC
Chambers Director Senior Clerk Clerks
Andrew Meyler Matthew Phipps Andrew Tull Jack May Louis Candy
John Mclaren Connor Curtin Emma Buckland Chloe Turvill Alex Fletcher Kelly Shaer
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