Savage v South Essex Partnership NHS Foundation Trust [2006] EWHC 3562 (QB), [2007] All ER (D) 148 (Feb)
Where someone dies as the result of alleged clinical negligence and it is alleged that there has been a breach of the European Convention on Human Rights, Art 2 (the right to life), the proper test is one of at least gross negligence of a kind sufficient to sustain a charge of manslaughter.