In Health Care Complaints Commission v Fraser [2014] NSWCATOD 29 it was asserted that a practitioner (Fraser, a nurse and midwife)  knew or was recklessly indifferent to the fact that a former medical practitioner was not registered at the time of administration of alternative cancer therapy or that she administered intravenous vitamin therapy without the order of a registered medical practitioner.

The Tribunal found that there were serious and significant departures from the standard expected of a practitioner, of that practitioner’s training and experience. Professional misconduct was found, with protective orders to be made at a later date.

The decision was later affirmed on appeal.