A rare abuse of the emergency exception involves patients who have refused to consent to specific medical care. The refusal may be based on religious beliefs, such as refusing blood transfusions, or on a personal decision, such as refusing intensive care. If the physician disagrees with such a decision, the time to fight the decision is when it is made. There is no legal justification for waiting until the patient is unconscious or for physically or chemically restraining a patient and then rendering care against the patient’s consent. This would not constitute an emergency exception to the need for consent. On the contrary, it would constitute battery. The solution in these cases, as discussed later in this section, is to apply to the courts for permission to treat against the patient’s consent.