Is Compensation for Medical Negligence Adequate? SC Explains!

Key Judicial Interpretation

The Supreme Court clarified that compensation for medical negligence must be just and adequate, taking into account the prolonged suffering and deficiency in service, rather than merely symbolic amounts (paras 12-16).

Court’s View

The Court held that the reduction of compensation by the State Commission and the NCDRC was unjustified, given the recognized deficiencies in post-operative care and the prolonged suffering of the appellant. The original award by the District Forum was deemed appropriate (paras 14-16).

Conclusion

The Supreme Court set aside the awards of the NCDRC and the State Commission, restoring the District Forum’s award of Rs. 5 lakhs to the appellant, with 9% interest from the date of the award and Rs. 50,000 in litigation costs (para 18).

Relevant Acts, Sections, Provisions, and Rules Cited

Sections 12 of the Consumer Protection Act, 1986

Case of the Appellant

The appellant, Jyoti Devi, argued that the persistent pain and complications following her appendicitis surgery were due to medical negligence by Suket Hospital and Dr. Anil Chauhan, and sought adequate compensation for her prolonged suffering.

Appellant Relied On

The appellant relied on medical records indicating the presence of a foreign body (needle) and the subsequent surgeries and treatments required due to the negligence.

Case of the Respondent

The respondents, Suket Hospital and Dr. Anil Chauhan, contended that the needle was not left during the surgery at their hospital and that the appellant had received treatment from multiple other hospitals, making it difficult to attribute the negligence solely to them.

Respondent Relied On

The respondents relied on the argument that the pain and complications could be attributed to treatments received at other hospitals and challenged the direct causation of negligence on their part.

Question & Answer

Question: What did the Supreme Court rule regarding the compensation for medical negligence?
Answer: The Supreme Court ruled that compensation must be just and adequate, restoring the District Forum’s award of Rs. 5 lakhs, with 9% interest and additional litigation costs, considering the prolonged suffering and deficiency in post-operative care (paras 12-16, 18).

Question: Why did the Supreme Court set aside the awards of the NCDRC and the State Commission?
Answer: The Supreme Court found the reduced compensation unjustified given the acknowledged deficiencies in medical care and the appellant’s prolonged suffering, deeming the original award by the District Forum appropriate (paras 14-16).

Question: What was the significance of the ‘eggshell skull’ rule in this case?
Answer: The Supreme Court noted the NCDRC’s misapplication of the ‘eggshell skull’ rule, as there was no evidence of a pre-existing condition making the appellant unusually susceptible to harm from the surgery (para 17).

Question: What does the Consumer Protection Act aim to achieve, according to the Supreme Court?
Answer: The Consumer Protection Act aims to protect consumers’ interests by providing inexpensive and prompt remedies for grievances against defective goods and deficient services, ensuring justice and fair compensation (para 12.1.1).

Question: How did the Supreme Court view the responsibility of medical practitioners in this case?
Answer: The Supreme Court emphasized that medical practitioners are liable for negligence when their conduct falls below the standard of a reasonably competent practitioner, impacting the patient’s health and causing harm (para 12.2.1).

Details of Case

Court: Supreme Court of India
Bench: Justice Sanjay Karol, Justice Aravind Kumar
Date of Order: April 23, 2024
Case Name: Jyoti Devi vs. Suket Hospital & Ors.
Case No.: Civil Appeal No. _____ of 2024 (Arising out of SLP (C) No. 242 of 2016)