In a landmark legal case before the Supreme Court of India, the issue of medical negligence was brought to light in the dispute between the Suket Hospital & Others and the Claimant-Jyoti Devi. The Court’s examination of the negligence leading to significant suffering of the appellant for over five years, including the presence of a foreign body in the abdomen, culminated in a crucial judgment regarding compensation and liability. The case delves into the nuances of the Consumer Protection Act, 1986, and explores the true extent of medical responsibility in such situations.
Facts
- The case involves the suffering of the claimant-appellant for over five years due to negligence of the medical practitioners.
- The District Consumer Disputes Redressal Forum awarded compensation of Rs. 5,00,000 for the injury suffered by the appellant.
- A foreign body (needle) was found in the appellant’s abdomen necessitating further surgery for removal.
- The H.P. State Consumer Disputes Redressal Commission held the hospital liable for the pain and suffering caused to the appellant.
- The National Consumer Disputes Redressal Commission criticized the post-operative care provided by the hospital as falling short of standard medical care.
- The NCDRC did not accept the argument that care received from multiple hospitals made it difficult to determine responsibility for the foreign body in the appellant’s abdomen.
- The egg-skull rule was applied to hold an individual liable for all consequences of their act.
- The compensation awarded by the State Commission was enhanced to Rs.2,00,000/-.
Also Read: State of Karnataka v. Jairaj: Quashing of FIR Reversed by Supreme Court
Analysis
- The dispute arose under the Consumer Protection Act, 1986, with negligence by the Hospital and another party acknowledged.
- The suffering period of more than 5 years was contested, leading to a review of the awarded compensation.
- The argument against medical negligence centered on a gap of 1½ years without pain, supported by lack of contrary evidence.
- The State Commission and District Forum had differing views on the needle presence, but NCDRC affirmed its existence and criticized post-operative care by the Hospital.
- The respondents did not appeal to the Court, leaving the findings and compensation subject to judicial review.
- Appreciation of pronouncements of the Court on the scope and purpose of the Consumer Protection Act is essential
- Understanding of medical negligence and compensation in such cases is important
- The ‘eggshell skull’ rule in tort law also needs to be considered
Also Read: Scrutiny Committee’s Decision Upheld in Caste Certificate Controversy
Case Title: JYOTI DEVI Vs. SUKET HOSPITAL AND ORS. (2024 INSC 330)
Case Number: C.A. No.-005256-005256 / 2024
