The Supreme Court (SC) has recently reiterated that a doctor cannot automatically be held liable for medical negligence simply because a patient's treatment or surgery was unsuccessful. In a recent ruling, a bench of Justices Sanjay Kumar and Satish Chandra Sharma emphasized that the failure of a treatment or surgery does not automatically equate to medical negligence. The court set aside an order from the National Consumer Disputes Redressal Commission (NCDRC) that had found a doctor guilty based on a ground not initially raised by the complainant.
The case in question stemmed from a complaint filed in 2005 by Manmeet Singh Mattewal following the death of his wife, Charanpreet Kaur, and their newborn son. Charanpreet Kaur was admitted to Deep Nursing Home for delivery, but complications arose, leading to the death of the newborn shortly after birth and the mother's subsequent death due to profuse bleeding. Mattewal alleged negligence, claiming the nursing home was ill-equipped and that there was a delay in arranging a blood transfusion.
The Supreme Court, however, dismissed the complaint and directed Mattewal to refund the ₹10,00,000 he had received as compensation. The court's decision was influenced by reports from five successive Medical Boards that found no gross medical negligence in the case. The Court referenced the principles established in Jacob Mathew vs. State of Punjab, stating that a doctor cannot be held liable simply because a patient did not respond favorably to treatment or if a surgery failed. The Supreme Court also noted that no sensible professional would intentionally commit an act that would result in harm or injury to a patient because their reputation is at stake.
Furthermore, the Supreme Court found that the NCDRC had overstepped its jurisdiction by building a new case based on antenatal negligence, which was never the subject of the original complaint. The court emphasized that consumer commissions cannot decide a case on grounds that were not raised in the pleadings. The Supreme Court clarified that the NCDRC's focus was on the antenatal care and management of the patient, even though the original complaint concerned post-delivery negligence.
The ruling underscores the importance of distinguishing between genuine medical negligence and unfavorable treatment outcomes. The court cautioned against the over-judicialization of medical disputes and highlighted that courts and consumer forums should not substitute their own views for those of medical experts. While acknowledging that some doctors may prioritize financial gain over their Hippocratic Oath, the court stressed that the entire medical community should not be judged based on the actions of a few.
This judgment aligns with previous rulings, such as Jacob Mathew v. State of Punjab and Martin F. D'Souza vs. Mohd. Ishfaq, which emphasize that medical professionals should not be held liable unless there is strong evidence of negligence. The court reiterated that the principle of res ipsa loquitur ("the thing speaks for itself") should not be applied mechanically in medical negligence cases. The Supreme Court's decision provides important clarification on the complexities of medical negligence cases and offers reassurance to medical professionals who strive to provide the best possible care.
