In making a decision on penalty, the College of Physicians and Surgeons of Nova Scotia looked at sanctions in similar cases from the '90s. But while penalties then may be different than what would apply today, the ethics regarding sex with patients were just as definitive.
Dr. Charles George Duncan, who practised in Niagara, Ont, 'took advantage of his patients’ vulnerability. The power imbalance weighed heavily in his favour, and he used it to the detriment of his victims,' the judge said during his sentencing hearing.