Medical Negligence: Supreme Court's Landmark Ruling on Hospital Liability

By Abhishek Jat, Advocate

The Supreme Court of India recently delivered a significant judgment concerning vicarious liability of hospitals in cases of medical negligence. In a noteworthy decision in The Managing Director, Kamineni Hospitals v. Peddi Narayana Swami & Anr. (Civil Appeal arising from SLP (Civil) No. 2948-2949 of 2023), the apex court upheld the finding of liability against the hospital while modifying the compensation amount awarded to the aggrieved family.

Case Background

The litigation stemmed from a tragic incident involving a 27-year-old B.Tech graduate who lost his life allegedly due to medical negligence at Kamineni Hospitals. The deceased's father filed a consumer complaint, leading to proceedings before the Andhra Pradesh State Consumer Disputes Redressal Commission (APSCDRC) and subsequently, the National Consumer Disputes Redressal Commission (NCDRC).

The NCDRC had imposed a substantial liability of ₹15 lakhs on the hospital and ₹5 lakhs on the treating physician, Dr. J.V.S. Vidyasagar, totaling ₹20 lakhs as compensation to the bereaved family. This determination prompted the hospital to approach the Supreme Court, challenging both the finding of negligence and the quantum of compensation.

The Hospital's Contentions

The appellant hospital contended that no medical negligence could be attributed to their institution or the doctors involved in treating the deceased. They argued that:

1. The standard of care expected of medical professionals was duly observed
2. All procedures followed were in accordance with established medical literature
3. Necessary consents were obtained from the patient's attendants
4. No evidence from medical experts substantiated the findings of negligence

The hospital further maintained that the compensation amount was disproportionately high and lacked evidentiary support.

Court's Analysis

The bench comprising Justices B.R. Gavai and Augustine George Masih meticulously examined the medical records and evidence presented. After thorough deliberation, the Court affirmed that there was "ample evidence as well as records to indicate that there was indeed medical negligence" on the part of the hospital and the treating physician.

The Court gave particular attention to the deceased's profile—a young professional at 27 years of age with a B.Tech degree, employed in a soap factory and financially supporting his family. Noting that young professionals often start with "humble short steps" in their careers, the Court recognized his potential for future earnings and advancement.

Modification of Compensation

While upholding the finding of negligence, the Court modified the compensation amount payable by the hospital. During the pendency of proceedings, the Supreme Court had directed the hospital to deposit ₹10 lakhs, which had appreciated with interest over time. Taking this into account, the Court deemed it appropriate to fix the hospital's liability at ₹10 lakhs plus accrued interest, rather than the ₹15 lakhs awarded by the NCDRC.

This nuanced approach balanced the hospital's culpability with practical considerations regarding compensation already deposited. The treating physician's liability of ₹5 lakhs remained unchanged, as he had accepted the NCDRC's judgment and deposited the amount.

Implications for Healthcare Institutions

This judgment reinforces several important principles in medical negligence jurisprudence:

1. Vicarious Liability: Hospitals bear responsibility for negligent acts of healthcare professionals practicing within their premises
2. Standard of Care: Medical institutions must ensure adherence to established protocols and procedures
3. Compensation Assessment: When determining compensation, courts consider not just current earnings but potential future income, particularly for young victims
4. Evidentiary Requirements: Medical records and treatment history serve as crucial evidence in establishing negligence

The ruling underscores the judiciary's commitment to balancing the interests of medical institutions with the rights of patients, ensuring accountability while avoiding unduly punitive measures.

Conclusion

The Supreme Court's judgment in this case provides valuable guidance on the contours of hospital liability in medical negligence cases. By affirming the finding of negligence while calibrating the compensation amount, the Court has demonstrated a measured approach to addressing medical malpractice claims.

For healthcare institutions, the ruling serves as a reminder of their duty to maintain rigorous standards of care and the potential consequences of falling short. For patients and their families, it reinforces the availability of legal remedies when medical care fails to meet established standards.