In the case of ECT, it can be argued that the requirement to include a placebo control is particularly compelling because there is a prima facie case for assuming that applying electrical currents to the brain may be harmful. Hence, if researchers are to adhere to the first injunction in the Hippocratic oath (primum nonnocere – first do not harm; Gillon, 1985), they must demonstrate that the electroshock is a necessary component of the therapy, and that the procedure is not only effective but safe. To do this, researchers must compare gains made by ECT recipients with gains made by people who thought they received ECT but did not (Ross, 2006).