Nevertheless, in looking to effectively advise Charlie, it is also to be appreciated that when the decision to refuse consent is a consequence of the his religious beliefs, under the ECHR 1950, Article 9 issues may arise, in relation to the protection of freedom of thought, conscience and religion, and, on the basis of the European Court of Human Rights’ (‘ECtHR’) decision in Hoffmann v. Austria. However, in spite of this, it must also be recognised that the European Commission in Arrowsmith v. UK had previously indicated ‘religious practice’ does not include every act motivated or influenced by a religion or set of beliefs. Nevertheless, complex issues arising from religious belief were possibly most effectively demonstrated in Re T whereby it was effectively recognised that an adult could refuse medical treatment. But T's mother was a Jehovah’s Witness who objected to blood transfusions and T accordingly refused to consent - although she was unaware this was the only means of saving her life. Therefore, with this in mind, the rest of T’s family applied to the courts for authorisation because it was in T’s ‘best interests’ to receive the transfusion in order to be able to stay alive.Although the decision in Re T would appear to imply Mr Dire would be able to carry out the blood transfusion with authorisation, however, Charlie still needs to be advised that this may still be considered to be somewhat inconsistent with Article 9 of the ECHR 1950. But still against that it must be recognised that where the patient’s condition is life-threatening the welfare of the patient will usually require blood products. Moreover, from the facts it is also important to appreciate that Charlie carried a card that effectively prohibited him from having a blood transfusion and, on the basis of the decision in Malette v. Schulman, it must be recognised that, conversely, where the situation is not considered life threatening, substantial damages may be awarded for mental distress. Therefore, with this in mind, since Charlie was carrying a card stating he did not want any blood products, it could have a similar effect to an ‘advanced directive’ and should have prevented him having a blood transfusion and entitle him to damages in keeping with the general compensatory principle underlying tort being that the successful claimant should receive damages to restore them to the position they would have been in had the tort never occurred.