There is no statute governing physicians’ tort liability based on lack of informed consent so traditional tort law of negligence should be applied. This Article begins by analyzing the courts’ opinions regarding the application of the second paragraph and the beginning part of the first paragraph of Article 184 of the Civil Code. It then exams two distinct standards of care to measure the sufficiency of physicians’ disclosures in informed consent cases. Finally, this Article addresses the courts’ opinions regarding the standards to determine the causation element of tort liability. By studying the courts’ cases, it tries to clarify the application of the informed consent law on tort liability and then offers suggestions that can be used by courts to analyze related issues in the future.