The Most Common VSBHK Disciplinary Charges: A 26-Year Data Analysis for Hong Kong Veterinary Surgeons

By Rendy Ng & Mary Wong | Rendy Ng Law Firm | Hong Kong

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Introduction

What gets a veterinary surgeon into trouble with the Veterinary Surgeons Board of Hong Kong ("VSBHK")?

To answer this question, Rendy Ng Law Firm has conducted a comprehensive analysis of every disciplinary decision published by the VSBHK from 2000 to March 2026. Across 116 cases, we identified 177 individual charge-type instances spanning 19 distinct categories.

This article sets out the findings of that analysis. It is designed not only for veterinary surgeons who are currently facing a complaint, but also as a practical prevention tool for clinic principals and practitioners who want to identify and close compliance gaps before a complaint is ever made.

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The Big Picture: What the Data Tell Us

The three most common categories of disciplinary charges together account for 62.7% of all charge instances, reflecting the VSBHK's consistent focus on clinical standards and documentation obligations. The full ranking, from most to least frequent, is as follows.

• Inadequate or Inappropriate Treatment is the single most common charge type, arising in 46 instances and representing 26.0% of all charge instances. It appears in roughly 40% of all disciplinary cases decided over the period.
• Inadequate Diagnosis or Failure to Diagnose is the second most common charge type, arising in 36 instances and representing 20.3% of all charge instances.
• Inadequate Medical Records is the third most common charge type, arising in 29 instances and representing 16.4% of all charge instances.
• Inappropriate Prescription or Medication Error is the fourth most common charge type, arising in 16 instances and representing 9.0% of all charge instances.
• Failure to Cooperate with the Veterinary Board has been charged in 7 instances, representing 4.0% of all charge instances.
• Falsification or Alteration of Medical Records, False or Misleading Certificates or Documents, and Inadequate Post-operative or Post-treatment Care have each been charged in 5 instances, each representing 2.8% of all charge instances.
• Inadequate Supervision of Staff or Clinic and Failure to Refer or Facilitate a Second Opinion have each been charged in 4 instances, each representing 2.3% of all charge instances.
• Performing a Procedure Without the Owner's Consent, Improper Anaesthesia, Criminal Conviction, and Defamatory or Unethical Non-clinical Conduct have each been charged in 3 instances, each representing 1.7% of all charge instances.
• Misrepresentation of Qualifications or Credentials, Practising Without a Valid Certificate, and Soliciting Business or Unfair Competition have each been charged in 2 instances, each representing 1.1% of all charge instances.
• Privacy Breach and Sexual Harassment have each been charged in 1 instance, each representing 0.6% of all charge instances.

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A Closer Look at the Five Most Common Charge Categories

1. Inadequate or Inappropriate Treatment — 46 Instances (26.0%)

Treatment-related charges are the most common category. The VSBHK has brought charges under this head across an exceptionally wide range of clinical situations. Our analysis identifies the following distinct sub-types:

(a) Substandard or incomplete spay or ovariohysterectomy surgery — 5 instances. This sub-type covers cases where the surgical technique was found to be deficient, including cases where residual ovarian tissue was left in the abdomen, where the wrong anatomical structures were ligated, or where wound closure was inadequate.

(b) Failure to remove a foreign body during surgery — 3 instances. This sub-type covers cases where gauze or swabs were left in a surgical site, or where a foreign body that was visible on pre-operative radiographs was not retrieved during an exploratory laparotomy.

(c) Failure to provide adequate emergency or acute treatment — 5 instances. This sub-type covers cases involving time-critical conditions including status epilepticus, post-operative haemorrhage, and acute respiratory distress, where the veterinary surgeon failed to administer the standard emergency protocol.

(d) Failure to provide adequate treatment for a diagnosed or presenting condition — general — 10 instances. This is the largest single sub-type and covers a broad range of cases where the treatment provided was found to fall below the standard expected of a reasonably competent general practitioner, across various conditions and species.

(e) Inappropriate surgical decision or substandard surgical execution — 7 instances. This sub-type covers cases where the decision to operate was itself inappropriate (for example, because the animal's condition was a contraindication to surgery), as well as cases where the surgery was performed negligently.

(f) Failure to manage or recognise post-operative complications — 4 instances. This sub-type covers cases where the veterinary surgeon failed to take adequate action in response to post-operative complications, including failing to recall a patient who was reported to be bleeding after discharge.

(g) Failure to make adequate arrangements for a hospitalised patient — 2 instances. This sub-type covers cases where a veterinary surgeon left a hospitalised animal without ensuring that adequate care arrangements were in place, including one case involving no overnight staffing.

(h) Inappropriate or delayed treatment for orthopaedic or spinal conditions — 2 instances. This sub-type covers cases where surgical intervention for a spinal or orthopaedic condition was delayed or not recommended when it should have been, causing deterioration in the animal's condition.

(i) Failure to adequately advise the owner on treatment risks or options — 3 instances. This sub-type covers cases where the veterinary surgeon failed to obtain informed consent, failed to advise the owner of the potential side effects of a proposed treatment, or failed to present the owner with adequate treatment options.

(j) Inappropriate treatment based on an incorrect or unsupported diagnosis — 3 instances. This sub-type covers cases where the treatment itself was a direct consequence of a diagnostic error, such as performing an ovariohysterectomy based on a wrong diagnosis, or recommending subcutaneous saline infusion for a patient with cardiac disease.

(k) Failure to adequately treat eye or limb conditions — 2 instances. This sub-type covers cases involving inadequate treatment of eye trauma, necrotic limb conditions, and leg injuries.

2. Inadequate Diagnosis or Failure to Diagnose — 36 Instances (20.3%)

Diagnostic failure charges are the second most common category. The VSBHK has found misconduct where veterinary surgeons failed to reach a correct diagnosis, used an inappropriate diagnostic method, or failed to properly interpret available diagnostic information. Our analysis identifies eight distinct sub-types.

(a) Failure to detect or correctly interpret radiographic findings — 7 instances. This covers cases where a foreign body, fracture, or area of necrosis that was visible on radiographs was missed, or where the radiographic images were not adequately reviewed before a clinical decision was made.

(b) Failure to consider or correctly identify cardiac or respiratory conditions — 4 instances. This covers cases where congestive heart failure, cardiogenic pulmonary oedema, or bradycardia was not considered as a differential diagnosis when the clinical presentation warranted it.

(c) Failure to diagnose orthopaedic conditions — 3 instances. Notably, three separate cases involved a failure to diagnose hip dislocation despite the availability of radiographs and a physical examination that should have revealed the condition.

(d) Use of an inadequate or inappropriate diagnostic method — 4 instances. This covers cases where the veterinary surgeon chose a diagnostic tool that was not appropriate for the clinical question being asked, the most notable example being the use of radiography rather than ultrasound to diagnose pregnancy at an early stage of gestation.

(e) Failure to diagnose gastrointestinal or oesophageal conditions — 4 instances. This covers cases involving missed oesophageal rupture and failure to identify the cause of urethral obstruction.

(f) Failure to provide adequate diagnosis — general — 8 instances. This covers cases across a variety of conditions where the Inquiry Committee found that the diagnostic process was insufficient, without the failure being attributable to a single specific cause.

(g) Failure to conduct adequate pre-operative assessment or examination — 3 instances. This covers cases where a veterinary surgeon proceeded to surgery or an invasive procedure without conducting the pre-operative workup that the animal's condition required.

(h) Failure to identify drug side effects or contraindications during the diagnostic process — 3 instances. This covers cases where the veterinary surgeon failed to recognise that a patient was showing signs of adverse effects from a drug already being administered, including corticosteroid toxicity and hypercalcaemia.

3. Inadequate Medical Records — 29 Instances (16.4%)

Medical record charges are frequently brought alongside treatment or diagnosis charges, but they are also charged as standalone counts. The VSBHK applies section 18 of the Code of Practice for Registered Veterinary Surgeons, which requires records to be contemporaneous, accurate, and sufficiently detailed. Our analysis identifies six distinct sub-types.

(a) Failure to record vital signs, physical examination findings, or clinical observations — 8 instances. The Inquiry Committee has consistently held that a clinical record must include heart rate, respiratory rate, mucous membrane colour, hydration status, and body weight, particularly for hospitalised animals.

(b) Failure to record differential diagnoses, clinical reasoning, or treatment rationale — 6 instances. This covers cases where the record contained no explanation of why a particular drug was prescribed, what diagnoses were considered, or how the clinical decision was reached.

(c) Failure to record drug dosage details, treatment administered, or charges — 4 instances. This includes cases where there was a discrepancy between the drugs recorded as administered and the charges billed to the client.

(d) Failure to record surgical details, anaesthetic notes, or procedure documentation — 4 instances. This covers cases where the record of a surgical or anaesthetic procedure was absent or inadequate, including cases where no record was made of resuscitation attempts.

(e) Failure to record clinical progress during hospitalisation — 4 instances. This covers cases where daily progress notes for hospitalised animals were absent or insufficient.

(f) Failure to retain, manage, or provide radiographs or imaging records — 3 instances. This covers cases where radiographs or ultrasound images were lost, not retained, or not provided to the VSBHK upon request.

4. Inappropriate Prescription or Medication Error — 16 Instances (9.0%)

Medication-related charges cover a wide range of conduct, from prescribing the wrong drug to dispensing expired medication. Our analysis identifies six distinct sub-types.

(a) Prescription of an inappropriate or contraindicated drug for the animal's condition — 5 instances. Drugs that have featured in VSBHK charges include piroxicam, dexamethasone, human cold medicine, and oral CBD oil.

(b) Prescription of an incorrect drug dosage — 4 instances. Drugs where incorrect dosing has been charged include Malarone, Lasix (furosemide), Clavet, and meloxicam.

(c) Concurrent prescription of contraindicated drugs — 1 instance. This case involved the simultaneous prescription of meloxicam and prednisolone.

(d) Dispensing of expired or unlabelled medication — 2 instances. One case involved an expired ophthalmic ointment; another involved providing an unlabelled medication bottle.

(e) Failure to adequately supervise the medication labelling or dispensing process — 1 instance. This case involved allowing non-veterinary staff to label and dispense medications without veterinary oversight, resulting in incorrect labels.

(f) Inappropriate clinical decision constituting a medication error — 3 instances. This covers errors arising from a broader clinical misjudgement, including administering a blood transfusion without prior cross-matching.

5. Failure to Cooperate with the Veterinary Board — 7 Instances (4.0%)

This category is entirely within a veterinary surgeon's control — and yet it has been charged in seven separate cases. Our analysis identifies three sub-types.

(a) Refusal or failure to provide medical records or documents to the VSBHK despite written requests — 5 instances. In each of these cases, the VSBHK had made one or more written requests for records and the veterinary surgeon either refused outright or failed to respond within a reasonable time.

(b) Refusal to provide documents or information to the VSBHK to assist in its statutory functions — 1 instance. This case involved refusing to provide equipment guidelines requested by the VSBHK.

(c) Failure to report a criminal conviction to the VSBHK within the required 28-day period — 1 instance. Section 2.2 of the Code of Practice requires a registered veterinary surgeon who is convicted of a criminal offence to report that conviction to the VSBHK Secretariat within 28 days.

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What These Data Mean for You: Prevention Is Better Than Defence

The patterns that emerge from 116 decided cases tell a remarkably consistent story: the vast majority of disciplinary proceedings arise not from deliberate wrongdoing, but from gaps in clinical documentation, inadequate practice systems, and a failure to communicate clearly with clients. These are gaps that can be identified and closed before a complaint is ever made.

This is precisely where a lawyer with experience in veterinary regulatory law can add value well before any complaint arises. A pre-emptive legal review of your practice, sometimes called a compliance audit or risk review, can identify the specific areas where your current documentation, consent procedures, and clinic protocols fall short of what the VSBHK's Code of Practice requires. Based on the data in this article, the following are the four areas that warrant the closest attention.

• Medical records and documentation systems. Inadequate medical records account for 16.4% of all charge instances. In many of those cases, the records were not fabricated or deliberately withheld, they were simply never created in sufficient detail in the first place. A lawyer can review your current record-keeping templates and workflows against the requirements of section 18 of the Code of Practice and advise on what a contemporaneous, VSBHK-compliant clinical record should contain. Implementing a standardised record template is one of the single most effective steps a veterinary surgeon can take to reduce disciplinary risk.
• Client consent forms and disclosure procedures. Across the treatment and diagnosis categories, inadequate communication with the client is a recurring theme. A properly drafted, procedure-specific consent form does two things simultaneously: it ensures that the client has received and acknowledged the information they are entitled to, and it creates a contemporaneous record of that communication that can be produced in evidence if a complaint is later made. A lawyer can draft or review your consent forms and advise on the disclosures that the VSBHK requires.
• Staff supervision and clinic governance. Four cases in our dataset involved inadequate supervision of staff or clinic operations, including cases where non-veterinary staff were permitted to give medical advice, perform surgical procedures, or label and dispense medications without veterinary oversight. As clinic principal or responsible veterinarian, you carry personal disciplinary liability for the conduct of the staff under your supervision. A legal review of your clinic's internal protocols can identify governance gaps before they become the subject of a complaint.
• Certificates, export documentation, and official statements. Five cases in our dataset involved false or misleading certificates or documents. In several of these cases, the veterinary surgeon did not act with any dishonest intent, the errors arose from carelessness, time pressure, or a misunderstanding of what a particular certificate required. A lawyer can advise on the legal obligations that attach to the various certificates you are routinely asked to sign, and help you put in place a checking procedure that reduces the risk of error.

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How We Can Help

The cost of a preventive legal review is a fraction of the cost, financial, professional, and personal, of defending a VSBHK disciplinary inquiry. Rendy Ng Law Firm has extensive experience advising veterinary surgeons on regulatory compliance and disciplinary defence.  

© 2026 Rendy Ng Law Firm. All rights reserved. This article is intended for general information purposes only and does not constitute legal advice. Readers facing a complaint or disciplinary proceeding should seek independent legal advice specific to their circumstances.

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