What is the standard of care required for a plaintiff to obtain consent from a surgeon?

The trial judge concluded that the surgical procedure performed was not a mini-abdominoplasty or mini tummy tuck, which is a cosmetic surgery ordinarily performed by a plastic surgeon. That finding was well-supported by the evidence and is not challenged on this appeal. Thus, it is not the appellant’s position on this appeal that the respondent performed surgery “to which there was no consent at all”, to use the words of Laskin C.J.C. in Reibl v. Hughes, supra. Rather, the appellant contends that the respondent performed surgery that was “beyond that to which there was consent”. This position has evolved since the action was begun.