Medical negligence occurs when a doctor breaches his duty of care owed to a patient, resulting in injury to the patient. For a claim of medical negligence to be successful, it must be proven that the doctor owed a duty of care, breached this duty, and this breach caused damages to the patient. Some examples of breaches include failing to take an x-ray, misdiagnosis, or leaving surgical tools inside a patient's body. The standard of care owed depends on the doctor's level of training and experience. Between 1985-1989, the Malaysian Medical Council inquired into 36 cases of medical negligence and disciplinary issues, finding 21 practitioners guilty.