A COMPARATIVE ANALYSIS OF LEGAL STANDARDS FOR INFORMED CONSENT IN NIGERIA AND THE UNITED KINGDOM AND ITS IMPLICATIONS ON PATIENT AUTONOMY

ABSTRACT This study examined the legal and ethical dimensions of informed consent in medical practice, with a comparative focus on Nigeria and the United Kingdom. It traced the historical evolution of informed consent, identified its core elements, underlying ethical principles, and theoretical models. The study explored the international and regional instruments that shaped informed consent standards, before analysing the domestic legal frameworks in both jurisdictions. Through a comparative legal approach, it assessed the implications of these standards on patient autonomy, highlighting the extent to which each system protected the rights, dignity, and decision-making capacity of patients. The research employed doctrinal methodology, relying on primary sources such as legislation, case law, and treaties, as well as secondary literature including scholarly articles and ethical guidelines. The scope of the study was limited to healthcare contexts, with particular attention to the doctor–patient relationship. Findings revealed both convergences and divergences in the legal regulation of informed consent, as well as practical challenges in implementation, particularly in Nigeria. The study concluded by recommending best practices drawn from comparative insights to enhance the protection of patient autonomy and to ensure compliance with ethical and legal obligations in medical decision-making.