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A patient may lawfully leave the facility only in one of two ways: by pass issued by doctor or if patient discharges themselves.
“a patient may lawfully leave the facility only in one of two ways. But later ... the doctor ... tells us about the possibility of nurses also issuing passes”
The doctor changed the account on how passes are issued, including nurses issuing passes, which was not in the first affidavit and came only after being presented with different evidence.
“which is a very fundamental change from the first affidavit. You do not need to have been presented with this data ... to make an accurate statement ... that in fact what he said was not correct because the facility protocol is not followed, that in fact the practice of keeping records is that it is just not honoured”
The doctor made a categorical statement that people go out of the facility only in two lawful ways: pass by doctor or self-discharge, which contradicts later statements about nurses issuing passes.
“a patient may lawfully leave the facility only one of two ways. But later ... the doctor ... tells us about the possibility of nurses also issuing passes”
In a supplementary affidavit, the doctor stated that if he is not available to authorize passes, then nurses will do so, which is a fundamental change from the first affidavit.
“if he is not available then the nurses will authorise. So which is a very fundamental change from the first affidavit.”