The Health Professions Appeal and Review Board has issued a decision regarding a dispute between two medical professionals in Ontario, stemming from the treatment of a patient who is herself a family physician1. The case, which involves allegations of medical negligence and racial bias, centered on the care provided following a traumatic accident in the spring of 2021. The applicant in the matter, Dr. Balakrishna Naidoo, a retired paediatrician and former coroner, sought a review of a previous decision made by the College of Physicians and Surgeons of Ontario. That initial decision had declined to take disciplinary action against Dr. Sophie Lynne Corriveau, a specialist in respirology and internal medicine who treated Dr. Naidoo’s daughter at Hamilton General Hospital. Following a comprehensive review of the investigative record and the clinical standards of the profession, the Board ultimately confirmed the original decision to take no further action against the respondent physician, while emphasizing the professional obligation to treat all patients with equal compassion.
The events leading to the legal challenge began on April 27, 2021, when Dr. Naidoo’s daughter was involved in a serious horseback riding accident. During the incident, she was thrown from the horse and the animal subsequently stepped on her abdomen, causing significant internal injuries. She was initially transported to Guelph General Hospital for stabilization before being transferred to Hamilton General Hospital for specialized care. During her stay in Hamilton, the patient was under the care of several different medical teams. Dr. Corriveau became involved in the case on May 18 and 19, 2021, serving as the on-call staff attending physician for the Internal Medicine Service. It was during this short window of care that many of the contentious interactions and medical decisions occurred, leading Dr. Naidoo to file a formal complaint against Dr. Corriveau and four other physicians involved in his daughter’s recovery2.
Dr. Naidoo raised a substantial list of concerns regarding the quality of care his daughter received. Among these was the allegation that a diagnosis of blunt abdominal trauma was rejected despite it being the primary reason for her admission. He further contended that the medical team ignored evidence of atelectasis, which is a partial collapse of the lung, even though it had been identified by radiology reports. The complaint also alleged that the patient’s chest and lungs were not properly examined despite her reporting difficulties with breathing. Dr. Naidoo argued that the severity of the respiratory component of her injury was minimized and that there was an over-reliance on pulse oximetry. He specifically noted that pulse oximetry is known to be less reliable in individuals with darker skin tones and argued that the results should have been verified with arterial blood gas sampling.
Beyond the respiratory concerns, the complaint touched on several other clinical issues. Dr. Naidoo alleged that fluid collections in the patient’s liver, pancreas, and pleura were unrecognized or ignored. He also raised issues regarding the management of abdominal drainage tubes and the treatment of low sodium levels, known as hyponatremia. The applicant claimed that his daughter was kept without oral or intravenous fluids for an extended period, leading to dehydration. Furthermore, he expressed concern that the patient’s reports of hallucinations, potentially a side effect of opioid pain medication, were not addressed by the attending staff. Most significantly, Dr. Naidoo alleged that the patient faced hostility and dismissiveness from the medical team, suggesting that she received a lower standard of care due to racial bias because she is a Black woman.
In response to these allegations, Dr. Corriveau provided a detailed written account of her involvement in the patient’s care. She clarified that the medical team was fully aware of the mechanism of the injury, noting that blunt abdominal trauma is an event rather than a specific diagnosis. She explained that the team focused on managing the specific internal injuries revealed by imaging, such as a high-grade liver laceration and hematomas in the pancreas and duodenum. Regarding the respiratory issues, Dr. Corriveau stated that she did acknowledge the lung collapse in her medical notes, describing it as a left lower lobe collapse. She maintained that she performed physical examinations, including auscultating the patient’s chest, and determined that the decreased breath sounds were consistent with known small pleural effusions. She asserted that the patient’s oxygen levels were normal on room air and that more invasive testing, like arterial sampling, was not clinically indicated at that time.
Dr. Corriveau also addressed the concerns regarding fluid management and the allegations of bias. She explained that the low sodium levels were interpreted as a result of fluid loss from diarrhea and poor intake, and that she ordered appropriate rehydration with careful monitoring to avoid complications. She denied that the patient’s breathing difficulties were ever dismissed as anxiety or attention-seeking behavior. Regarding the claim of racial bias, Dr. Corriveau stated that she had reviewed the educational materials provided by the College of Physicians and Surgeons of Ontario, including articles on implicit bias in healthcare and the importance of recognizing that Black patients often face systemic barriers. She expressed her confidence that she provided appropriate and unbiased care to the patient during their interactions.
The Inquiries, Complaints and Reports Committee of the College investigated the matter by reviewing hospital records from both Guelph and Hamilton, the physician’s responses, and relevant College policies. The Committee eventually decided that no further action was necessary, a conclusion that Dr. Naidoo appealed to the Health Professions Appeal and Review Board. In his request for a review, Dr. Naidoo emphasized his own decades of experience as a paediatrician and coroner, stating that his goal was not to seek a specific punishment but to improve the awareness of the physicians involved. He argued that there were clear shortcomings in clinical skills and a failure to recognize cultural biases that could affect medical judgment. He also criticized the composition of the Committee’s panel, suggesting that it should have included specialists in internal medicine and respirology.
The Board’s mandate in this review was to determine whether the College’s investigation was adequate and whether its decision to take no action was reasonable. An investigation is considered adequate if it seeks out the essential information required to make an informed decision. The Board found that the College had obtained all necessary medical records, complaint letters, and physician responses. It noted that Dr. Naidoo had been given multiple opportunities to clarify his concerns. The Board also addressed the composition of the panel, explaining that the Committee’s role is to screen complaints using its collective expertise to determine if a referral to a discipline tribunal is warranted. There is no legal requirement for the panel to consist of members with the exact same specialty as the physician being investigated.
In assessing the reasonableness of the decision, the Board looked for a coherent and rational connection between the facts and the conclusion. It noted that for nearly every clinical concern raised by Dr. Naidoo, the medical records provided a contemporaneous account that supported Dr. Corriveau’s defense. For instance, the records confirmed that the patient’s oxygen saturation was 97 percent on room air, which supported the decision not to perform more invasive arterial testing. The Board emphasized that medical records are legal documents and are generally considered reliable sources of information about what occurred during a patient encounter. Because the records did not show evidence of clinical negligence or a failure to monitor the patient’s condition, the Board determined it was reasonable for the Committee to conclude that no professional misconduct had occurred.
The allegation of racial bias presented a more complex challenge for the Board. The Committee had acknowledged that it could not know with absolute certainty how every interpersonal interaction between the patient and the physician unfolded. It recognized that racial or cultural bias in medical settings can be either conscious or unconscious. However, the Board found that because the clinical record did not show a lack of care, and because there was no direct evidence of racial animus in the documents, the Committee’s decision to take no action was justified within its role as a screening body. Despite this, the Board saw fit to confirm the Committee’s statement regarding the expectation of equal treatment. This statement serves as a reminder to all physicians in Ontario that they must ensure all patients are treated with respect regardless of their race, gender, or socioeconomic status.
The final decision by the Board confirms that the original investigation into Dr. Corriveau was sufficient and that the conclusion reached by the College of Physicians and Surgeons of Ontario was within the range of reasonable outcomes. By confirming the decision, the Board has brought a legal close to this specific complaint. The ruling underscores the high level of deference given to the clinical findings documented in hospital records during the complaint review process. While the Board validated the physician’s clinical decisions based on the available data, it also validated the applicant’s right to have his perceptions of bias heard and acknowledged. The case concludes with the Board’s formal expectation that physicians must remain vigilant against discriminatory factors in the delivery of healthcare to the public.
Read more cases about proceedings in regulated professions here.
- Naidoo v Corriveau, 2026 CanLII 26 (ON HPARB) ↩︎
- To review the Board’s decisions concerning the other four doctors, the cases are as follows:
Naidoo v Passos, 2026 CanLII 28 (ON HPARB)
Naidoo v Pai, 2026 CanLII 31 (ON HPARB)
Naidoo v Sne, 2026 CanLII 27 (ON HPARB)
Naidoo v Rice, 2026 CanLII 30 (ON HPARB) ↩︎
