Maybe this, European Court of Human Rights decision, should be kept in mind.
"Whilst it was arguable that doctors had a duty not to falsify medical records under the common law (Sir Donaldson MR’s “duty of candour”), before Powell v Boladz there was no binding decision of the courts as to the existence of such a duty.
As the law stands now, however, doctors have no duty to give the parents of a child who died as a result of their negligence a truthful account of the circumstances of the death, nor even to refrain from deliberately falsifying records." The decision can be accessed from
this page searching for
"
decision" and "application no.
45305/99" to see -
DECISION
AS TO THE ADMISSIBILITY OF
Application no. 45305/99
by William and Anita POWELL
against the United Kingdom