What is the current state of the law on disclosure of material risks?

In Rawlings v. Lindsay (1982), 20 C.C.L.T. 301, Madam Justice McLachlin also dealt with the terminology of risks. She said at p. 306: The terminology of "material", "special", and "unusual" risks has in the past given rise to confusion. However, a fair summary of the effect of those decisions, in my view, is that a medical person must disclose those risks to which a reasonable patient would be likely to attach significance in deciding whether or not to undergo the proposed treatment. In making this determination, the degree of probability of the risk and its seriousness are relevant factors. Thus an "unusual" or improbable risk should be disclosed if its effects are serious. Conversely, a minor result should be disclosed if it is inherent in or a probable result of the process.