Australian Dental Journal

The official journal of the Australian Dental Association

Australian Dental Journal 2012; 57:(1 Suppl): 9–15

doi: 10.1111/j.1834-7819.2011.01653.x

Contemporary medico-legal dental radiology

B Wright*
*Barrister-at-Law, Brisbane, Queensland.

ABSTRACT
The advent of extraoral radiology in general dental practice has become more widespread since 2000, particularly with
digital systems. With this comes a range of medico-legal risks for dentists not adverted to previously.
These risks include a higher than expected radiation dose for some surveys, and the risk of a ‘loss of a chance’ for a
patient whereby the images may disclose pathology not diagnosed by general dental practitioners using OPG and CBVT
radiology.
Practitioners need to apply relevant legal principles in deciding which surveys to order and record, and also need to
explain to patients the dosages of the radiation that they will likely receive. Practitioners also need to assess whether the
resultant survey ought to be interpreted by a radiologist to diagnose any wider pathology with which a general
practitioner may not be familiar. Extra caution needs to be used in ordering high dose radiology in paediatric patients.
Dentists should not assume patients fully understand the nature of CBVT and MCT, and its risks and benefits.
Consideration ought to be given to the volume of CBVT ordered dependent on factors such as patient age, symptoms,
history and procedural intent.
Keywords: Legal, radiography.
Abbreviations and acronyms: CBVT = cone beam volume tomography; MCT = medically computed tomography; OPG =
orthopantomograms; TMJ = temporomandibular joint.

ramifications of ordering and interpreting images for

INTRODUCTION
dental practice and consent in relation to radiology.
Prior to 2000, general dental practice radiology was There are significant risks for patients from the
largely limited to interpreting intraoral film-based radiation dose as well as benefits from relevant
images. It was normal practice for orthopantomograms information to be gained from radiology, and both
(OPGs), lateral cephalography and temporomandibular these issues are particularly heightened with reference
joint imaging using plane films or tomography to be to extraoral imaging, especially with CBVT.
referred to specialist medical radiology practices, or The legal risk that attaches to the interpreter of large
teaching institutions. Some orthodontic practices volume tomography (typically for a general dentist
recorded their own analogue images. using CBVT) will be assessed and the minimization of
The introduction of affordable digital equipment such risk for dental practitioners who own and operate
allowing sophisticated radiology, with advances in CBVT equipment, interpret their own CBVT data sets
software for dental imaging in recent years has seen and order extraoral radiography examinations will be
the creation and growth in Australia of the dental discussed.
specialty of dentomaxillofacial radiology. These ser- Licences to take dental radiographs and possess oral
vices include acquiring and interpretation of intraoral radiography machinery vary in each state or territory of
digital imaging, orthopantomography, medically-based Australia. It is worth noting that the national health
helical scan computerized tomography (MCT) and cone practitioner registration system did not (and perhaps
beam volume tomography (CBVT). could not) make arrangements for more consistent
Australian dental practitioners are licensed to both regulations in relation to possession and use of
create images as an oral radiographer and interpret as radiology machines. The need to register with state
oral radiologists. This paper will address some legal bodies with very different regulations is a significant
ª 2012 Australian Dental Association 9
B Wright

impediment to the free flow of oral health practitioners as radiation dose) can only be decided with an
from one jurisdiction to another. It is hoped that this examination of the particular circumstances of each
inconsistency will be diminished. clinical event. It is therefore meaningless to say
that, for example, an OPG survey is the ‘standard
of care’.
LEGAL NATURE OF RADIOLOGY
In a situation where the proximity of a third molar
It is well accepted that when one decides to record a apex to the inferior dental canal can be better
radiograph, despite the fact that there is no physical visualized with CBVT prior to extraction, the decision
touching, exposing a patient to ionizing radiation can as to whether a CBVT ought to be ordered would
be deemed to be an assault or battery.1 Because ionizing surely always be an example of practitioner applica-
radiation is invisible, there is arguably a higher duty tion of knowledge and skill to the particular
that the practitioner must observe in relation to circumstance. In such a circumstance, common sense
informing patients about radiology compared to other would dictate that a discussion ought to take place
diagnostic services. with the patient as to the benefits of the extra
Factors that increase this duty compared to other information gained from the CBVT, compared with
dental treatment include: the extended period between the risk of the higher dose of radiation. Of course if
exposure and any presenting pathology; patients’ the decision is made not to image with CBVT and
general lack of understanding about ionizing radiation there is a paraesthesia that ensues after the removal of
and in particular dosages of different radiographs; the the tooth, the burden of proof in relation to causation
rapid changes in technology with both decreases for will still sit with the patient. But these questions are
some dosages in dental radiology and increases in other often not legal questions. They are better answered by
forms; and changes in the resultant recommendations consideration of what ought to be done for the
for diagnostic protocols. patient. Also, it is clear that merely recording a CBVT
Unfortunately, as much of legal radiology process will not stop the occurrence of a paraesthesia, it will
and direction comes from the USA, some American potentially merely give better information about how
legal terms have crept into the Australian health care to avoid the outcome and give information that is
lexicon. ‘Informed consent’ and ‘standard of care’ are useful in deciding how to execute the extraction, or
two notable examples. whether to refer to a more experienced or specialist
Informed consent is a term specifically disavowed by practitioner. As radiation levels decrease with this
Australian courts: ‘‘… the phrase ‘informed consent’ is imaging compared to an OPG radiograph, the need to
apt to mislead as it suggests a test of the validity of a address the radiation issue decreases and there is more
patient’s consent … Moreover, consent is relevant to likelihood that CBVT will be ordered. However, a full
actions framed in trespass, not in negligence. Anglo- volume CBVT might not be appropriate if a small
Australian law has rightly taken the view that an volume CBVT were available.
allegation that the risks inherent in a medical procedure As CBVT becomes more widely available, there will
have not been disclosed to the patient can only found an be instances where a patient may well ask why they
action in negligence and not in trespass; the consent were not given an opportunity to have a three-
necessary to negative the offence of battery is satisfied dimensional CBVT radiograph.
by the patient being advised in broad terms of the
nature of the procedure to be performed.’’2
Material risk
By using the term standard of care, there is an
erroneous suggestion that there is some omnipresent With similar particularity, valid consent to a radiolog-
‘standard’ (perhaps more widely accepted because of ical procedure can only be determined with the
recently introduced Practitioner Standards and Codes particular procedure and particular patient in mind.
of Practice across various jurisdictions); but the truth is To paraphrase Rogers v. Whitaker:2 ‘‘… a dental
something far less concrete. practitioner has a duty to warn a patient of a material
The Bolam3 test as modified in Australia by common risk inherent in the proposed treatment … a risk is
law and legislation – basically the reference to widely material if, in the circumstances of the particular case, a
accepted professional practice as a means of defining reasonable person in the patient’s position, if warned of
the particularly appropriate level of care, with some the risk, would be likely to attach significance to it
statutory and judicial limitations for extremes of (objective limb) … or … if the dental practitioner is
opinion – is what is used to establish a particular aware or should reasonably be aware that the particular
standard in a particular individual clinical case where patient, if warned of the risk, would be likely to attach
negligence is asserted in the delivery of treatment. significance to it (subjective limb) …This duty is subject
To remove any doubt, the standard of procedural to the therapeutic privilege (meaning in instances where
care (as opposed to warning of material risks – such there is an emergency or other special situation).’’
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 Contemporary medico-legal dental radiology

stances on referral from dental practitioners to the

Records
provision of OPG radiology reports.
Radiological records belong to the practitioner provider
who recorded them or was responsible for recording
OPG radiography and radiology and risk
them.4 In most cases this is the dentist or oral
radiologist, or interestingly perhaps ultimately the In terms of dosage for dental imaging, the risks for film
owner of the practice, now that owners are not and digital radiology are low compared to medical
necessarily practitioners – so that there may be a radiography. It may be that after a discussion of
modern dichotomy of ownership and access. effective dose for a digital OPG, no further discussion
Of course, now that much radiology is digital many needs to be held if the patient is satisfied with the
people can apparently own, retain and control images explanation in terms they can understand. A discussion
simultaneously. No matter that multiple copies exist, of comparative doses to background radiation can be
ownership resides with the practitioner and provision useful. The benefit of the information that can be
of copies need always be done with the provisions of gained by the low dose needs to be explained. Showing
the relevant privacy legislation firmly in mind. Requests patients a de-identified OPG image can also be very
for images ought to be provided only with a valid helpful in conducting an inclusive risk–benefit analysis.
signed request or release form. For the general dentist, the main medico-legal risk is
Radiographs – like all dental records – ought to be lack of diagnosis of pathology that may have been clear
stored for at least 7–10 years past the age of 21, but the to an oral radiologist.
community might well expect that permanent life-long Whilst it is clear that examining intraoral radio-
retention of records is the norm. Although there is no graphs for detection of decay or periodontal disease in a
legal requirement to archive, rather than dispose of clinical practice requires a degree of experience and
records, in this digital age it is advisable to keep all knowledge, often the radiographs are examined whilst
records to assist with future treatment, to defend any treating patients and not with the requisite time and
negligence claim, or to assist with a request for post- appropriate viewing conditions allocated to the task.
mortem identification. Radiographs ought to be reviewed with appropriate
lighting and without interruption in the way that
radiologists examine radiographs. If intraoral radio-
Radiology versus radiography
graphs are negligently read and give rise to an action in
Dentistry remains one of the health professions that negligence (over-treatment of carious lesions, or failing
generally has the responsibility for requesting radiolog- to diagnose a lesion), the overall risk to the patient’s
ical studies, exposing the radiographs, and interpreting general health is quite low and legal consequences
the results, and finally making decisions based on the correspondingly small. In addition, the ability to prove
results and interpretation. The specialty of dentomax- a diagnosis as correct or otherwise from an intraoral
illofacial radiology has grown over the last 10 years radiograph – digital or film – is based on training that
through postgraduate training in dental schools in all Australian trained dentists receive in radiography
universities where specialist oral radiologists are trained and radiology for their undergraduate education.
and who provide consultant services, usually in con- When OPG radiographs are exposed and examined,
junction with specialist medical radiology practices. the structures that are included for examination extend
far wider than the alveolar processes compared to
intraoral radiological surveys. Specifically, the wider
Intraoral versus extraoral radiography
tissues can involve malignancies and other pathologies.
Dentists in general practice have always been respon- It seems obvious that unless dentists or radiologists
sible for the exposure and interpretation of intraoral examine the surveys and do so with appropriate time
radiographs, simply because referring these patients to and focus, there will be pathologies that will not be
radiological services would make the cost of dentistry detected and as such legal risks may arise. Obviously,
much higher. Medical radiology services and the some training in detecting these non-dental pathologies
efficiency of their delivery is a significant constraint in ought to be mandatory.
general dentistry. In fact, many dental procedures are There is extraoral radiography and radiology training
completely dependent on intraoral radiology and available in relatively few locations and the different
impossible to adequately perform without it; these jurisdictions across Australia have widely differing
include endodontics, emergency pain relief and implant requirements for regulating equipment, licenses and
therapies. installations. This seems driven by the fact that
Extraoral radiology – at first principally OPGs – although no Medicare rebate generally attaches to the
came to medical radiology imaging practices because of OPG taken in private dental practice, the ability to see
the Medicare rebate that attaches in certain circum- an image and interpret it instantly is a great benefit for
ª 2012 Australian Dental Association 11
B Wright

general practitioners. Many radiological imaging (5) If responsibility is found to reside with dentists with
practices do not provide digital images as they print extraoral machines, what minimization of the legal risk
films for interpretation, although this is changing and improved patient outcomes can be effected.
gradually. Inevitably, the provision of the images from
a radiologist on referral is such that there is a significant Negligence
delay from the time of referral to viewing of the image,
The two types of likely negligence claims that will arise
and this will always remain at issue for general dental
from oral radiology relate to dosage and failure to
practitioners.
diagnose.

Non-OPG extraoral radiology

Dosage
With the development of tomography, radiographic and
The tort of negligence is well understood by most
diagnostic services have expanded. Initially, CT scan-
dental practitioners and patients. The aspects of the tort
ners and other tomography were so expensive that they
that are perhaps most applicable in the current situation
were usually owned and operated by medical radiology
of dosage are causation, reasonable foreseeability and
imaging businesses. The advent of relatively low-cost
warning of material risk.
CBVT, an increase in competition and an increase in
The causation of an injury needs to be proven.
sales and marketing by dental companies, has led to the
Alternatively, the injury might well speak for itself in
current situation where dentists own and operate CBVT
that a dosage of radiation that is high initially, and if
scanners. The principle medico-legal risks for practitio-
repeated, could give rise to a claim for damages. Whilst
ners operating these machines arise when radiation
it would not be easy for a claimant to prove injury and
doses are not fully explained to patients and when the
causation from CBVT diagnostic imaging, the likeli-
practitioner does not report on or consider the whole
hood would increase with paediatric patients and
data sets and wider areas of exposure, and limit their
repeat exposure patients. Australian courts have been
interest to the area in question. By way of example, if a
reluctant to give damages where causation is compli-
dentist wishes to place a single implant but captures
cated in relation to a loss of a chance.5
much more area, they should examine the wider area
The irrefutable fact is that the operation of CBVT
and not simply the small space where the implant will be
without appropriate regulation and guidance will see a
placed. Often it is the case that the dentist does not
higher dosage of radiation delivered to a patient base as
know the dosages the patient receives, and has no
a whole but more particularly to certain individuals.
training in diagnosing and reporting on the ‘non-dental’
The issue of reasonable foreseeability (and to some
areas.
extent remoteness of damage) will be one of fact, and
Dentists generally either refer patients to radiology
will be determined by retrospective studies in the
providers or use their own machines (usually CBVT) to
future. Currently, this is hard to determine and makes
record data sets and then review the dentally relevant
a successful suit more difficult.
sections of the data set. In machines with large volume
In 1996 Webb et al. found that 50% of patient
capacity, large doses of radiation can be delivered to
radiation exposure came from full body CT.6 O’Hare
provide a whole of head exposure, but only a very small
surmised that the availability of multislice CT has almost
amount of the data set might ever be examined and
certainly increased the potential for litigation, particu-
reported upon. In machines with lower volume or
larly in paediatric patients who have a two to three times
operator-adjustable volume, the issues are less serious
greater likelihood of radiation induced cancer than
because the data set is not as comprehensive, and also
adults.7 Moss and Maclean surveyed 53 scanners and
the dosage is much lower.
found the effective dose varied by up to 36 fold.8 O’Hare
This raises the following issues to be resolved:
cites the lifetime mortality risk from a single CT to a one-
(1) Whether the exposure of patients to large doses of
year-old child has been held to be as high as 1:550.9
radiation is appropriate for the diagnostic purpose.
As to material risk and warnings, the wider question
(2) Whether dentists are responsible for the review of the
of ionizing radiation dosages across a person’s circum-
whole data set and are therefore additionally responsible
stances would be critical in discussing risk and this
for identifying and diagnosing all of the possible findings
would include, but not be limited to, occupation and
that are available as a result of that survey.
environmental considerations (long haul airline crew or
(3) Whether dentists and patients know the received
radiographers would have a different risk profile to that
effective dose from these machines and who is respon-
of a city office worker), diagnostic and therapeutic
sible for managing this in the minds of patients,
radiation history, and patient age and gender.
regulators or tribunals.
In cases of general CT radiology, the risks are greater
(4) Types of consent to be gained for OPG and CBVT
and the duty to inform is clearer. Cardinal et al.
surveys.
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 Contemporary medico-legal dental radiology

explored the issue of informing patients of risks and Friedland’s paper contemplates most of these issues –
benefits of radiological examinations: ‘‘In addition to albeit from a US perspective.13 It is of guidance and the
the need to educate patients, studies have underscored section on field of view, reproduced below, is apposite
the need to better educate referring physicians, demon- to questions of appropriate ordering and selection of
strating that referring physicians often have limited field of view.
knowledge of the radiation dose and associated risks ‘‘One of the issues raised by CBCT is just which
for common radiologic examinations. This is unfortu- anatomical area of the jaws and head or neck should be
nate, for two reasons. First, this knowledge is relevant included in a study. For example, assume one takes a
for appropriate medical decision making in ordering CBCT scan of the fully edentulous maxilla for purposes
radiologic examinations. Second, referring physicians of evaluating the feasibility of placing implants. Does
are well positioned to initiate patient education on the the image provide sufficient coverage if the beam is
risks associated with these examinations. Referring collimated (in the vertical) to include just the alveolar
physicians often have good pre-existing relationships bone and only 2 to 3 mm superior to the sinus floor? Or
and well-developed lines of communication. They also is it necessary to include more of or perhaps even the
should understand the benefits of the radiology exam- entire sinus? The general principles of radiology dictate
ination they are ordering for particular patients and that the taking of films be based on clinical indications
have the opportunity to involve the patients in the and that examinations not be done as part of ‘a fishing
decision-making process further upstream. By the time expedition’.’’
patient education can occur in the radiology depart- ‘‘The rationale for this is to protect both the
ment, a patient may have taken time off work and made individual patient’s and the public health from unnec-
a long trip to the radiology department, and completing essary radiation. Thus, in the example above, if the
the examination may be a foregone conclusion.’’10 patient has no sinus symptoms and no sinus pathology
This is a practical application of the principle that is suspected on clinical examination, there is not a
responsibility for the damages that flow from such a strong argument for including the whole sinus. The
referral do not necessarily sit singularly with the answer to how large an area to cover also includes,
radiologist or the dentist. If a dentist refers a patient however, the desires of the treating clinician, although
for radiology for the investigation of pathology, the this should not generally override well-accepted prin-
more serious the suspected pathology, the higher the ciples of radiation hygiene. In the above example, some
duty there is to follow up and check that the patient did clinicians may insist on seeing all the way to the orbital
have the referred investigation performed. There is floor. Further, some software programs require that
Australian authority that the duty of care to a patient certain anatomic landmarks be included since the
extends much wider to the referral and even follow up program uses them as (anatomical) fiduciary markers.’’
of patients.11 ‘‘It is also possible to collimate too narrowly, either
accidentally or by design, and thus to exclude structures
that reasonably ought to be included. The issue of
Failure to diagnose
purposely collimating too narrowly is closely related to
The issue of failure to diagnose in radiology can be the reading or interpretation of the films, an issue
characterized as a loss of chance. However, that loss of discussed in depth below. CBCT machines are increas-
chance must be a matter of a determination of ingly being marketed to private practitioners who are
probability. In a case about failure to diagnose a breast not oral and maxillofacial radiologists. Companies’
cancer, it was held that: ‘‘A mere material increase in target market is especially orthodontists and practitio-
the risk of injury followed by the eventuation of the risk ners who place dental implants. These practitioners
in question is insufficient to establish causation. The typically do not have sufficient training to interpret the
plaintiff must establish that it was probable that the risk films beyond the confines of their specialty or daily area
created by the tortfeasor came home.’’12 of practice. Some practitioners believe that one way to
In other words, for a loss of a chance, an increase in overcome the issue of interpretation is to collimate
the risk of a death from, for example, pathology which down to the smallest area possible. For example, if an
was undiagnosed from a CBVT, will not of itself be orthodontist does a CT to evaluate an impacted
enough to prove that the failure to diagnose caused the maxillary canine, the idea would be to collimate the
patient death. It must be more likely than not that the beam to include just the tooth and nothing superior or
failure to diagnose substantially caused the death. inferior to it. The danger with this approach, however,
However, does a dental practitioner have a respon- is that one may miss pathology that is contributing to
sibility to diagnose other pathology from a CT scan? the noneruption or impaction of the tooth. Similarly,
Does the dentist take on that responsibility by ordering when radiographing the temporomandibular joint
a CT scan that has a volume that is larger than the area (TMJ), if one were to collimate too narrowly, one
of interest? could potentially miss pathology that is not located
ª 2012 Australian Dental Association 13
B Wright

directly on or in the condyle or glenoid fossa, but that is somewhat stronger. It may be the case that whether one
contributing to the TMJ problem. In principle, the orders a CBVT survey for dental treatment or not, the
anatomical area covered by a CT scan should be no patient might well have a reasonable expectation to
different than would have been covered by a plain-film have interpretation (of all the data available) performed
examination. The extent of the examination should be as a matter of right – to reinforce the view of Friedland.
based on the patient’s symptoms and the findings on It would seem that if one refers a patient (and ⁄ or their
clinical examination.’’ image) to an oral radiologist, the responsibility for the
Friedland also addressed the issue of responsibility expertise in reading and interpreting that radiograph
for interpretation: ‘‘While there are no legal cases resides with the radiologist. Of course, the wording of the
specifically concerning the matter of the scope of referral will be determinative of where the responsibility
interpreting a CBCT scan, the issue can fairly be lies for which structures and the interpretation of the
regarded as settled. A CT is no different than any other image in relation to those structures.
image—a dentist cannot read only part of a panoramic
film, or only part of a lateral cephalogram. For
Digital and film radiography
example, should an orthodontist miss an enlarged sella
turcica resulting from a tumor on a lateral cephalo- In a case discussed by O’Hare, a misidentification
gram, the dentist reading the cephalogram cannot offer occurred subsequent to a death as a result of mislabel-
as an excuse in any legal proceeding that ‘I read only ling of film radiographs.15 A body was released when
part of the film’ or ‘I read the film only as it relates to identification was not correct. The importance of these
the orthodontic diagnosis and treatment’. The dentist is cases is that manual labelling of film after the recording
obligated to read all of the film … Moreover, in of a radiograph is clearly more prone to error than the
determining the standard of care, courts look to what conventional digital system whereby a patient’s details
the practice in the profession is, and as is evident from are entered or selected prior to the exposure of the
the editorial referenced above, the practice is to read all image.
of the film. Courts are not likely to allow a lower In addition, the dosages of a properly calibrated and
standard of care than the profession demands of itself.’’ operated digital system are widely accepted to be
Whilst this is no doubt a fair assessment of the law in significantly lower than a comparable film system,16
the USA, it is by no means certain to be applied in despite some reported inconsistencies with systems
Australia. However, it would be likely to be of (PSP v. Sensor) and the accommodation of changes
significant influence and guidance. The issue of whether by clinicians to digital systems.17
patient choice can be involved was also addressed.13 Increases in resolution in both sensors and monitors
‘‘While patients may make treatment decisions, their mean that there is less reason to persist with film for
choices are limited by the bounds of accepted standards dental intraoral procedures.
of care. No dentist would permit a patient to agree to
fill only two canals on a molar tooth undergoing
SUMMARY AND RECOMMENDATIONS
endodontic treatment and then to place a crown
because the dentist is unable to navigate the third canal (1) Dentists who refer patients for CBVT and OPGs
or because the patient can only afford to have two need to explain the risks of radiation dosages.
canals filled. Such a scenario would call for a referral to (2) Dentists who record OPGs and CBVT in their own
an endodontist or foregoing the crown. The same premises with their own machines also need to explain
principles apply to the interpretation of films.’’ dosages and risks, but with a higher duty than those
If it is accepted that dentists must ensure that after a merely referring.
wide-area survey the patient has a complete diagnosis, (3) Dentists who record OPG radiographs must take
and the dentist lacks the skills and experience to responsibility for all non-dental diagnosis from such
provide this, it is logical that it be referred to an oral or images or alternatively have them assessed on referral
medical radiologist. In the USA, no national dental by an oral radiologist or medical radiologist and
regulations mean that radiology telemedicine is quite include this cost in their estimate of fees to the patient.
difficult. No such barriers exist in Australia. (4) Dentists who record small volume CBVT for
It has been established in the High Court case of diagnostic purposes need to make assessments as to
Chappel v. Hart,14 that when making treatment whether all of the data set and possible information has
decisions, there is a responsibility on the treating been viewed and appropriately interpreted and whether
practitioner to advert as to whether the procedure (in referral to an oral radiologist is appropriate for viewing
the present case, reading of a radiology image) in the the data set.
particular circumstances could not be better performed (5) Dentists who record large volume CBVT (with no
by a more experienced practitioner. As oral radiologists variable volume options) in their own premises with
become more prevalent, the onus to refer becomes their own machines need to refer all data sets to an
14 ª 2012 Australian Dental Association
 Contemporary medico-legal dental radiology

appropriate radiologist for review and include this cost 10. Cardinal JS, Gunderman RB, Tarver RD. Informing patients
about risks and benefits of radiology examinations; a review
in their estimate of fees to the patient. These dentists are article. J Am Coll Radiol 2011;8:402–408.
at most medico-legal risk.
11. Tai v. Hatzistavrou [1999] NSWCA 306.
(6) Dentists should not order CBVT without appro-
12. Sydney South West Area Health Service v. Stamoulis [2009]
priate individual discussion of dosage related risks for NSWCA 153.
all paediatric patients. 13. Friedland B. Medicolegal issues related to cone beam CT. Semin
(7) Dentists with their own CBVT machines ought not Orthod 2009;15:77–84.
ordinarily order or expose CBVT for paediatric patients. 14. Chappel v Hart [1998] HCA 55.
15. O’Hare WSJ. Medico Legal Radiology. Elsevier Australia,
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2. Rogers v. Whitaker (1992) 175 CLR 479.
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ª 2012 Australian Dental Association 15