Negligence was not perceived as tort until 1932. However, the development of this doctrine can be traced back to the rulings of House of Lords in the case of Donoghue v Stevenson. This case was concerned with what was claimed to be the decomposed remnants of a snail in a bottle of ginger beer. Despite its generally late starting, Miller has verbally expressed that negligence is the most tort actions. The standard of care established in Donoghue v Stevenson could have been restricted and only applicable to the manufacturers of food and beverages who should have a duty of care towards the consumers. Notwithstanding, the court have decided to apply the guideline laid down in Donoghue v Stevenson to circumstances where duty of care is required. It is, therefore, the standard of Donoghue v Stevenson has been extended to include healthcare professionals who is expected to owe a duty of care towards the patients. In medical case, the focal inquiry that emerges is regardless of whether a specialist has accomplished the standard of care that is needed by law. The anticipated standard is of “reasonable care”. Truly, there has been hesitance with respect to the judiciary to discover specialists blameworthy of medical negligence. This may due to the mindset of doctors should be shielded from being charged under medical malpractice. This was demonstrated in Hatcher v Black, where Lord Denning, who is regarded as a well-kenned adherent of the medical vocation, described negligence as