The Supreme Court ruled that doctors can only be held liable for negligence when lacking the necessary qualifications or skills, or failing to apply reasonable expertise in treatment. The court emphasized that complications alone do not prove negligence, setting aside an earlier judgment of the NCDRC that awarded compensation.
New Delhi: In a recent ruling, the Supreme Court of India emphasized that a doctor can only be held liable for negligence if there is evidence of inadequate qualifications, lack of requisite skill, or a failure to exercise reasonable expertise in treating a patient. The decision, made by a bench consisting of Justices P.S. Narasimha and Pankaj Mithal, reinforced the importance of distinguishing between adverse outcomes and actionable medical negligence.
The bench noted that when a medical professional extends “reasonable care, expected of the medical professional, unless proven otherwise,” the outcome would not be categorized as actionable negligence.
“A medical professional may be held liable for negligence only when he is not possessed with the requisite qualification or skill, or when he fails to exercise reasonable skill which he possesses in giving the treatment,”
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the court stated.
This clarification from the Supreme Court comes as it overturned a decision by the National Consumer Disputes Redressal Commission (NCDRC) that had previously held a doctor liable for negligence. The case involved a minor who underwent a corrective surgery for a congenital eye disorder at the Post Graduate Institute of Medical Education & Research (PGIMER) in Chandigarh. The complainant alleged that the surgery, performed by Dr. Neeraj Sud in 1996, worsened the boy’s condition instead of improving it.
The Case Details and Allegations
The parents of the minor filed a complaint against Dr. Sud, accusing him of failing to perform the surgery correctly, resulting in further complications. They contended that a minor operation on the child’s left eye would have sufficed to correct the diagnosed deformity and claimed that post-surgery, the boy’s condition had deteriorated. The procedure in question was intended to lift the child’s left eyelid to align it with the right, but according to the complainants, the surgery failed to deliver the expected outcome.
Initially, the State Consumer Disputes Redressal Commission dismissed the complaint against Dr. Sud and PGIMER, ruling there was insufficient evidence to establish negligence. Dissatisfied, the complainants appealed to the NCDRC, which reversed the state commission’s decision and held both the doctor and the hospital “jointly and severely liable” for medical negligence, awarding a compensation of Rs. 3 lakh to the complainants and an additional Rs. 50,000 for the treatment’s inadequacy.
In response, Dr. Sud and PGIMER filed an appeal with the Supreme Court, seeking relief from the NCDRC’s ruling. Simultaneously, the complainants petitioned the court to review the NCDRC’s judgment further.
Supreme Court’s Observations on Medical Negligence
The Supreme Court observed that no substantial evidence was presented to establish negligence on the part of Dr. Sud or PGIMER. The bench underscored that not every adverse outcome can be classified as negligence, especially in complex procedures where complications may arise despite a doctor’s best efforts.
The court clarified that in surgeries or medical treatments,
“it is not necessary that in every case the condition of the patient would improve, and the surgery is successful to the satisfaction of the patient.”
In rare instances, complications might occur, but this does not necessarily indicate that the medical professional acted negligently.
“It is very much possible that in some rare cases complications of such nature arise, but that by itself does not establish any actionable negligence on the part of the medical expert,”
the bench explained. The Supreme Court further stated that without sufficient proof of incompetence or lack of skill on Dr. Sud’s part, the complainants could not claim compensation. Consequently, the court dismissed the negligence claims and denied the compensation awarded by the NCDRC.
Implications of the Verdict
This ruling by the Supreme Court sets a precedent in India for evaluating claims of medical negligence, where evidence of incompetence or a breach in the standard of care is essential for establishing liability. By emphasizing the need for concrete proof of negligence, the court aims to protect qualified and skilled medical professionals from unwarranted claims, which could arise from factors outside their control.
The verdict reinforces the notion that a medical professional’s obligation is to provide reasonable care and skill as expected within their field, and not every unfavorable outcome should be perceived as malpractice. The court’s emphasis on the importance of compassionately balancing patient expectations with the realities of medical risks is likely to influence future judgments in similar cases.
The case underscores that while patients have the right to quality medical care, doctors also deserve fair treatment under the law, especially when they act within their professional standards. This decision serves as a reminder of the judiciary’s role in safeguarding both patient rights and the integrity of the medical profession, ensuring a balanced approach to claims of medical negligence.
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