the testimonies of defence witnesses. Even if it is accepted that she was not an entirely satisfactory witness and her version should be disregarded, the question remains, namely, did the defendant on the version of the defence witnesses, having regard to the concessions made, discharged its onus to prove informed consent was given by the plaintiff on a preponderance of probabilities ? I think not. 37 [72] In respect of the third plaintiff it appears from the notes made on 13 October 2005 that the third plaintiff was in a prolonged first stage of labour and the plan decided by the doctors was for her to undergo a caesarean and a sterilisation. Dr Krönke testified that in her capacity as a consultant she would not have obtained any consent from the third plaintiff. [73] Dr Sichimwa testified that he must have explained the sterilisation procedure to the plaintiff. He further testified that he had assumed from the notes made by Dr Krönke on 30 March 2005 that the sterilisation procedure was canvassed with and explained to the plaintiff on that day. This was an incorrect assumption based on the evidence of Dr Krönke. Dr Sichimwa conceded that he had no independent recollection of what was specifically said to the plaintiff and had to rely on his notes. There is no reason apparent from the medical records why a sterilisation procedure was performed. His reason for failing to make notes is a poor excuse. [74] Nurse Tjimbundu testified that the doctors would decide the required treatment in respect of a specific patient. The impression which is gained from the evidence of defence witnesses who had testified regarding what information is conveyed during group sessions in respect of family planning and regarding the different contraception methods appear to sufficient information and that individual counselling is not only unnecessary but also impractical. Nurse Tjimbundu’s evidence contradicted this impression where she testified that family planning at group sessions would not constitute counselling in any sense and that individual counselling is still required. [75] The importance of proper and complete record keeping is best demonstrated if one has regard to what happened in respect of the third plaintiff. As conceded by Dr Krönke during cross-examination there is no indication in all the hospital records that the plaintiff had given consent at any time before her surgery. 38 [76] Regarding the consent forms signed by the plaintiff this was another demonstration where a patient was required to sign consent forms during the height of labour. It was accepted, for the reasons mentioned by the witnesses, that such a practice is highly undesirable.