In Montgomery v Lanarkshire Health Board [2015] UKSC 11 the Supreme Court redefined the standard of disclosure in informed consent to medical treatment, rejecting the application of the doctor-focused Bolam standard in favour of one focused on what was significant to patients. In Grimstone v Epsom and St Helier University Hospitals NHS Trust [2015] EWHC 3756 (QB), despite acknowledging a new standard now applied, McGowan J nevertheless used the Bolam test to determine liability for non-disclosure. This illustrates ongoing judicial deference to the medical profession and this case commentary explores that decision and its implications.