Court’s Decision
The Supreme Court allowed the appeal filed by a doctor and a nursing home against findings of medical negligence in the death of a mother and her newborn. The Court held that the National Commission (NCDRC) erred in traveling beyond pleadings and inventing negligence during antenatal care when the complaint was only about post-delivery care. It ruled that multiple expert medical boards had found no gross negligence, and thus the orders of both NCDRC and State Commission (SCDRC) were unsustainable. The complaint was dismissed, and the complainants were directed to refund ₹10,00,000 in instalments already received in the litigation.
Facts
The case originated when a woman in her early thirties, employed as a bank manager on deputation as a lecturer, died along with her newborn during childbirth at a Chandigarh nursing home in December 2005. She had consulted the obstetrician at the nursing home during her pregnancy and was admitted for delivery on 21 December 2005.
The newborn died within minutes of birth. Soon after, the mother suffered atonic Post-Partum Hemorrhage (PPH), a known obstetric emergency. She was given transfusions and shifted to PGIMER, Chandigarh, but was declared dead on arrival.
Her husband filed a complaint in 2006 before the State Consumer Commission, alleging that the nursing home was ill-equipped, delayed arranging blood, had no emergency facilities, and mishandled her transfer to PGI. Compensation of over ₹95 lakh was claimed.
Issues
- Whether the doctor and nursing home were negligent in handling delivery and post-delivery care, leading to maternal and neonatal deaths.
- Whether the Consumer Fora were justified in finding medical negligence despite five expert Medical Boards holding otherwise.
- Whether the NCDRC was correct in introducing antenatal negligence when the complaint raised only post-delivery negligence.
Petitioner’s Arguments
The appellants (doctor and nursing home) argued that:
- The patient suffered atonic PPH, a rare but catastrophic complication, which did not respond to standard treatment.
- Multiple Medical Boards, including expert panels from Government Medical College and PGI Chandigarh, consistently opined that no gross negligence was committed.
- The complaint alleged post-delivery negligence, yet the NCDRC shifted grounds to antenatal mismanagement (failure to insist on certain tests), which was never pleaded.
- Medical records showed the patient’s blood group was recorded, transfusions were started promptly, and she was shifted with oxygen and blood running.
- Courts and consumer fora cannot act as medical experts or apply res ipsa loquitur merely because treatment failed.
Respondent’s Arguments
The complainant contended that:
- The nursing home was inadequately equipped to handle emergencies and had no stock of blood ready for transfusion.
- There was delay in arranging blood and shifting her to PGI, causing death.
- Informing the mother about the newborn’s death caused her shock and profuse bleeding.
- The doctor failed to gather crucial information about the patient’s earlier delivery and did not insist on standard hematological tests.
- The SCDRC rightly held negligence in not arranging blood beforehand, and the NCDRC correctly attributed negligence in antenatal care..
Analysis of the Law
The Court reaffirmed that medical negligence must be specifically proved and cannot be inferred from an adverse outcome. Reliance was placed on:
- Jacob Mathew v. State of Punjab (2005) 6 SCC 1 – A doctor cannot be held negligent merely because treatment fails; res ipsa loquitur is inapplicable in such cases.
- Martin F. D’Souza v. Mohd. Ishfaq (2009) 3 SCC 1 – Courts are not medical experts; negligence must be shown with strong evidence.
- Devarakonda Surya Sesha Mani v. Care Hospital (2022 SCC OnLine SC 1608) – Every death in a hospital does not imply negligence unless a lack of due care is clearly proved.
The Court emphasized the principle that Consumer Fora cannot go beyond pleadings to create a new case for complainants, citing Trojan & Co. v. Nagappa Chettiar (1953), Ram Sarup Gupta v. Bishun Narain Inter College (1987), and recent rulings in A.V.G.P. Chettiar & Sons v. T. Palanisamy Gounder (2002), Venkataraman Krishnamurthy v. Lodha Crown Buildmart (2024), and Rama Kt. Barman v. Mohd. Mahim Ali (2024).
Precedent Analysis
- Jacob Mathew (2005) – Protects doctors from liability where complications occur despite due care. Applied here to reject automatic presumption of negligence.
- Martin F. D’Souza (2009) – Consumer fora cannot substitute their judgment for medical experts; echoed here.
- Devarakonda Surya Sesha Mani (2022) – Requires proof of lack of due care; reiterated that not all deaths imply negligence.
- Trojan & Co. (1953) and Ram Sarup Gupta (1987) – Courts cannot decide cases outside pleadings. NCDRC erred in attributing antenatal negligence never alleged.
These precedents collectively safeguarded the appellants and guided the Court’s ruling.
Court’s Reasoning
The Supreme Court found that:
- Five separate Medical Boards constituted at the complainant’s behest did not indict the doctor or the nursing home for gross negligence.
- The SCDRC’s reliance on textbook extracts and conjectures was misplaced, and its suspicion of fabricated records was unsubstantiated.
- The NCDRC contradicted itself by finding no negligence during delivery and post-delivery care, yet holding the doctor liable for antenatal negligence not pleaded.
- Such overreach violated settled principles that courts and tribunals cannot create a new case beyond pleadings.
The Court stressed: “Every failure in treatment does not amount to negligence. Consumer fora cannot invent new grounds when complainants have not pleaded them.”
Conclusion
The Supreme Court set aside the NCDRC and SCDRC orders, dismissed the complaint, and directed the complainant to refund ₹10,00,000 in monthly instalments of ₹1,00,000, with the first three instalments to the insurance company and the rest to the doctor. No costs were imposed, and parties were left to bear their own expenses.
Implications
This judgment underscores crucial principles:
- Verified expert opinion outweighs suspicion—multiple medical boards clearing a doctor cannot be ignored.
- Consumer fora must stick to pleadings—they cannot construct new allegations.
- Medical negligence requires strong proof—adverse outcomes alone are insufficient.
The ruling strengthens protection for doctors against unwarranted liability while preserving accountability through clear evidence. It also curtails judicial overreach by consumer fora, ensuring fair trial principles in medico-legal disputes.
FAQs
Q1. Can a doctor be held negligent if a patient dies from complications like PPH?
No. The Court held that complications like atonic PPH, even if fatal, do not automatically establish negligence unless lack of due care is proved.
Q2. Did the Supreme Court hold the nursing home liable in this case?
No. The Court found no negligence on part of the nursing home, as multiple expert boards confirmed proper facilities and timely action.
Q3. Why was the NCDRC’s decision set aside?
Because it wrongly attributed antenatal negligence when the complaint alleged only post-delivery negligence, thereby exceeding pleadings and jurisdiction.