Two university students who were on practical placement with an osteopath underwent treatment by him, with boundary violations.
The Tribunal decision, cancelling the registration of the osteopath, also considered whether the treatment was clinically justified, whether informed consent was obtained ad whether sufficient records were kept.
At  the Tribunal commented that assessment or treatment of a person known to the practitioner, or a student on placement, is not necessarily improper. However at  -117]:
Taken together, these three patient accounts are of young women, each experiencing multiple layers of vulnerability or structural power imbalance in relation to the practitioner (as a student under his supervision who was not seeking treatment, a student training in his profession whose self-reported patient history strongly indicated anxiety and depression, a patient seeing him for the first time who was in extreme pain, and who also reported anxiety) who were briskly manoeuvred into clinically unjustified situations involving intimate touching. Consent is at the heart of all health care, but most especially that involving intimate touching, and the actions of the practitioner ensured that the women did not have time or space to reflect on, and possibly reject, his course of action…
…had the practitioner taken the time to explain and seek agreement to the proposed touching, any consent obtained would still arguably not be informed, as it would not have been based upon any objective clinical rationale or offer any health benefit to the patient.
Health Care Complaints Commission v Duggan (No. 2)  NSWCATOD 30
It appears that criminal charges were also brought: .