🔴 IMPORTANT CASE LAWS 

1. R v Blaue (1975, UK)

🔹 Facts:

• A young woman (Jehovah’s Witness) was stabbed by the accused.
• She refused a life-saving blood transfusion due to religious beliefs.
• She died.

🔹 Legal Issue:

Whether refusal of medical treatment breaks the chain of causation in homicide.

🔹 Judgment:

Court held:

• The attacker is still legally responsible for death.
• Refusal of blood transfusion does NOT break causation.

🔹 Principle:

“The defendant must take the victim as they find them.”

🔹 Importance:

• Recognizes religious refusal but does not absolve criminal liability.
• Shows autonomy does not shift legal responsibility of the offender.

2. Re T (Adult: Refusal of Treatment) (1992, UK)

🔹 Facts:

• A pregnant woman involved in a car accident needed blood transfusion.
• She refused due to religious influence from her mother (Jehovah’s Witness).

🔹 Issue:

Is refusal valid when influenced and not fully voluntary?

🔹 Judgment:

• Court allowed transfusion.
• Held refusal was not fully informed or voluntary due to pressure and medical condition.

🔹 Principle:

Consent/refusal must be informed, voluntary, and competent.

🔹 Importance:

• Introduced idea that courts can override refusal if autonomy is compromised.

3. Re C (Adult: Refusal of Medical Treatment) (1994, UK)

🔹 Facts:

• A mentally ill patient (schizophrenia) refused amputation of gangrenous leg.
• He was a Jehovah’s Witness.

🔹 Issue:

Can a mentally ill person refuse life-saving treatment?

🔹 Judgment:

Court upheld refusal because:

• Patient understood nature and consequences.
• He was still mentally competent for decision-making.

🔹 Principle:

Competence is task-specific, not diagnosis-specific.

🔹 Importance:

• Strong affirmation of autonomy of competent adults, even in life-threatening situations.

4. Airedale NHS Trust v Bland (1993, UK)

🔹 Facts:

• A young man was in a persistent vegetative state.
• Doctors sought permission to withdraw life support (including artificial feeding).

🔹 Issue:

Whether withdrawing treatment equals killing.

🔹 Judgment:

• Withdrawal of treatment allowed.
• Court distinguished between killing and letting die.

🔹 Principle:

Medical treatment can be withdrawn if it is not in patient’s best interest.

🔹 Importance:

• Reinforces patient dignity and medical consent doctrine.
• Supports idea that treatment is not compulsory.

5. In re T (1992, UK Court of Appeal)

🔹 Facts:

• A pregnant Jehovah’s Witness woman refused blood transfusion.
• She was influenced by her mother and emotionally unstable.

🔹 Judgment:

Court overruled refusal.

🔹 Principle:

Free will is essential for valid refusal; undue influence invalidates consent.

🔹 Importance:

• Courts may intervene where religious refusal is not truly independent.

6. Public Health Trust v Wons (1989, USA)

🔹 Facts:

• Adult Jehovah’s Witness with severe uterine bleeding refused transfusion.
• She was competent and conscious.

🔹 Judgment:

Court respected her refusal.

🔹 Principle:

Competent adults have constitutional right to refuse treatment even if death results.

🔹 Importance:

• Strong American constitutional protection of bodily autonomy.

7. Jehovah’s Witnesses v King County Hospital (1968, USA Supreme Court)

🔹 Facts:

• Parents refused blood transfusion for children.
• Hospital sought court permission.

🔹 Judgment:

Court allowed transfusion for minors.

🔹 Principle:

State has parens patriae power (protecting children’s welfare).

🔹 Importance:

• Religious freedom of parents cannot override child’s right to life.

8. Raleigh Fitkin-Paul Morgan Memorial Hospital v Anderson (1964, USA)

🔹 Facts:

• Pregnant Jehovah’s Witness refused blood transfusion.
• Risk to unborn child.

🔹 Judgment:

Court ordered transfusion.

🔹 Principle:

State interest in unborn child can override maternal refusal.

🔹 Importance:

• Shows limits of religious autonomy when third-party life is involved.

9. In re Brooks’ Estate (1966, USA)

🔹 Facts:

• Adult Jehovah’s Witness refused transfusion.
• Court still ordered transfusion.

🔹 Judgment (later criticized/reversed in principle evolution):

• Initially allowed forced transfusion.

🔹 Principle:

Earlier courts prioritized life over autonomy.

🔹 Importance:

• Shows historical shift from paternalism → autonomy.

10. European Court of Human Rights: Pindo Mulla v Spain (2024)

🔹 Facts:

• Jehovah’s Witness received blood transfusion against her written refusal during emergency surgery.

🔹 Judgment:

• Court held Spain violated:
  • Article 8 (private life)
  • Article 9 (religious freedom)

🔹 Principle:

Informed refusal must be respected even in emergencies.

🔹 Importance:

• Strong modern affirmation of patient autonomy in Europe.

⚖️ OVERALL LEGAL PRINCIPLES (Exam Ready)

✔ 1. Competent Adult Rule

• Adult can refuse blood transfusion even if death results.

✔ 2. Parens Patriae Doctrine

• State can override refusal to protect:
  • minors
  • mentally incompetent persons

✔ 3. Doctrine of Informed Consent

• Refusal must be:
  • voluntary
  • informed
  • competent

✔ 4. Public Interest Override

Courts intervene when:

• child is involved
• pregnancy risk exists
• unconscious patient has no valid directive

✔ 5. Autonomy vs Life Debate

Modern trend:

• Strong shift toward bodily autonomy
• But exceptions still exist

📌 FINAL SUMMARY

Freedom of religion protects refusal of blood transfusion, but it is not absolute. Courts worldwide draw a clear line:

• Adults → autonomy respected
• Minors/unconscious → state can intervene
• Compromised consent → courts override refusal