The Supreme Court of India has emphasized that a lack of favorable response to treatment does not automatically imply negligence on the part of the treating physician. In a recent ruling, a bench of Justices Sanjay Kumar and Satish Chandra Sharma overturned an order by the National Consumer Disputes Redressal Commission (NCDRC) that had awarded compensation in a case where the patient did not respond positively to the medical treatment.

The case, Deep Nursing Home and another v. Manmeet Singh Mattewal and others, stemmed from the unfortunate deaths of Charanpreet Kaur and her newborn son in December 2005 due to postpartum hemorrhage (PPH) at Deep Nursing Home in Chandigarh. The State Consumer Disputes Redressal Commission (SCDRC) initially found the nursing home and the doctor, Dr. Kanwarjit Kochhar, negligent for inadequate post-delivery care and awarded Rs. 20.26 lakh as compensation. The NCDRC upheld this decision in 2012 but shifted the entire liability to Dr. Kochhar, citing lapses in antenatal care.

However, the Supreme Court disagreed with the NCDRC's assessment. The court noted that several medical boards had cleared the doctor and the nursing home of negligence, stressing that an unsuccessful treatment outcome does not automatically indicate negligence. The Supreme Court criticized the NCDRC for constructing a new case based on antenatal negligence, which was beyond the scope of the original complaint that focused on post-delivery negligence. The Apex Court bench comprising Justices Sanjay Kumar and SC Sharma held that NCDRC had transgressed its jurisdiction in building a new case for the complainants, contrary to their pleadings.

The Supreme Court reiterated the established legal principles that a doctor cannot be held liable for medical negligence simply because a treatment or surgery was not successful. The court also underscored that consumer commissions should not decide cases based on grounds that were not initially raised in the pleadings. It was also pointed out that sometimes, despite best efforts, the treatment by a doctor may fail, but that does not mean that the doctor or surgeon must be held guilty of medical negligence, unless there is some strong evidence to suggest that he or she is.

The Supreme Court allowed the appeal, setting aside the orders of both the NCDRC and the SCDRC, and dismissing the original complaint. Manmeet Singh Mattewal, the deceased's husband, was directed to refund the Rs. 10 lakh he had received as compensation, in monthly installments.

The Supreme Court bench also underscored that no sensible professional would intentionally commit an act or omission that would result in harm or injury to a patient because the professional's reputation would be at stake, and a single failure may cost them dearly. While acknowledging the commercialization of the medical profession, the court held that the entire medical fraternity cannot be blamed or branded as lacking integrity or competence just because of some bad actors.

This ruling reinforces the protection of medical professionals against unsubstantiated claims of medical negligence. It clarifies that an unfavorable outcome alone is not sufficient grounds for establishing negligence and that consumer forums must adhere to the scope of the original complaint. The Supreme Court's observation aligns with previous judgments, such as Jacob Mathew Vs State of Punjab and another (2005) and Martin F D'Souza Vs Mohd Ishfaq (2009), which emphasize that doctors should not be held liable for failed treatments unless there is strong evidence of negligence. Courts and consumer forums are not experts in medical science and must not substitute their own views over those of specialists.