HEALTH LAW PROJECT

TOPIC – A STUDY ON MEDICAL NEGLIGENCE WITH SPECIAL

REFERENCE TO BOLAM AND JACOB MATHEWS CASE

SUBMITTED BY:

ROLL:
PAPER NAME: HEALTH LAW
COURSE CODE:
COURSE ID:
SEMESTER:
CLASS: THREE -YEAR LL.B.(HONS.)
FACULTY NAME:

Classification: Internal
 ACKNOWLEDGEMENT

I would like to extend my sincere thanks to, for being my trainer during the
preparation of this project and for giving me excellent guidance throughout this work
carried out under her guidance. For this project has not only allowed me to explore the
prescribed topic, but on a more personal level, has allowed me to think on my own on
a relatively new and less explored arena.

Being only novices initiated into the subject, I thank my Professor cum trainer for all
the support and insightful input provided during the entire length of this project

I would also like to extend my gratitude to the principal

for providing me with all the facility that was required.

I specially wish to thank my friends whose timely support and relevant critique gave
this project its essential structure and completeness, for were it not for their assistance,
this project would not have taken the form it has presently.

Last but not the least I thank my parents and the Almighty for their unseen support and
blessings.

Dated:
 INDEX

SL. Particulars Page

No. No(s).
1. Introduction 1

2. Constitutional Provisions Relating to Health 2

3. Introduction to Medical Negligence 3

4. Civil Liability & Medical Negligence 3-4

5. Criminal Liability & Negligence 4

6. When does the liability arise in case of Medical Negligence 5

7. Procedure to file Complaint pertaining to Medical Negligence 5-6

8. Case Studies on Medical Negligence 7-10

9. What does not amount to Medical Negligence 11

10. Remedies – Medical Negligence 12-13

11. Conclusion 14

12. Bibliography 15
 INTRODUCTION

Our parliament, the highest political institution in the country, has always been energetic to meet the
needs of the changing society. Due to urbanization and industrialization the social patterns of the
people are rapidly changing. The most. important part is that, with the changing society, the law
needs to be changed protecting the interests of the disadvantageous groups and the weaker sections.

The Indian Parliament has done much to improve the social patterns of citizens by enacting social
welfare legislations. These legislations are framed to achieve the goals set in our Constitution. The
different legislations have been made to protect different groups of people like women, children,
workers etc. Apart from the goals laid down in our Constitution, it also provides for a variety of
fundamental rights. Health being one of the most important fundamental right needs extra protection
by specific legislations.

Our Constitution also requires the State to ensure health and nutritional well-being of all people.
Before independence the health care sector was in dismal condition as the number of mortality rate
owing to diseases was high. But since independence the main emphasis has been the health care
sector. This has been made possible by enacting various legislations.

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 CONSTITUTIONAL PROVISIONS RELATING TO HEALTH

The main source of law in our country is the Constitution, which itself provides for health care of the
people.

The Preamble to our Constitution, serves the following two purposes: -

A) It indicates the source from which the Constitution derives its authority.

B) It also states the objects, which the Constitution seeks to establish and promote.

Hence it does not grant any power, but it gives a direction and purpose to the Constitution. These
socio-economic goals to be achieved are: to secure to all its citizens social, economic and political
justice, liberty of thought, expression, belief, faith and worship; equality of status and opportunity,
and to promote among them fraternity so as to secure the dignity of the individual and the unity and
integrity of the Nation. To give a concrete shape to these aspirations, the Constitution has a chapter
on Fundamental rights which guarantee certain rights to the people, such as, freedom of the person,
freedom of speech, freedom of religion, etc. The Supreme Court has held in the case of Samantha v.
State of Andhra Pradesh,1 that : “the Constitution envisions to establish an egalitarian social order
rendering to every citizen, social, economic and political justice in a social and economic democracy
of the Bharat Republic.” The goals and objectives of the Indian polity as stated in the Preamble are
sought to be further clarified, strengthened, and concretized through the Directive Principles of the
State Policy.

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 INTRODUCTION TO MEDICAL NEGLIGENCE

Recently, Indian Society is experiencing a growing awareness regarding patient’s rights. This trend
is clearly discernible from recent spurt in litigation concerning medical professional or establishment
liability, claiming redressed for the suffering caused due to medical negligence, vitiated consent, and
breach of confidentiality arising out of the doctor patient relationship.

Medical malpractice is professional negligence by act or omission by a health care provider in

which the treatment provided falls below the accepted standard of practice in the medical community
and causes injury or death to the patient, with most cases involving medical error.

Negligence is simply failure to exercise due care. The three ingredients of negligence are as follows:

1. The defendant owes a duty of care to the plaintiff

2. The defendant has breached this duty of care.

3. The plaintiff has suffered an injury due to his breach.

In case of medical negligence mostly the doctor is the defendant. Negligence is predominantly a
theory of liability concerning allegations of medical malpractice, making this type of litigation part
of the Tort Law.

CIVIL LIABILITY AND MEDICAL NEGLIGENCE

Negligence is the breach of a legal duty to care. It means carelessness in a matter in which the law
mandates carefulness. A breach of this duty gives a patient the right to initiate action against
negligence. Persons who offer medical advice and treatment implicitly state and undertake to have
the skill and knowledge to do as under:

 To undertake a particular job.

 To decide whether to take a case or not,

 To decide the treatment suitable for particular case.

 To administer that treatment.

This is known as an “implied undertaking” on the part of a medical professional.

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However, no human being is perfect and even the most renowned specialist could make a mistake in
detecting or diagnosing the true nature of a disease. A doctor can be held liable for negligence only if
one can prove that she/ he is guilty of a failure that no doctor with ordinary skills would be guilty of
if acting with reasonable care. An error of judgment constitutes negligence only if a reasonably
competent professional with the standard skills that the defendant professes to have, and acting with
ordinary care, would not have made the same error.

Doctors must exercise an ordinary degree of skill. However, they cannot give a warranty of the
perfection of their skill or a guarantee of cure. If the doctor has adopted the right course of treatment,
if she/ he is skilled and has worked with a method and manner best suited to the patient, she/ he
cannot be blamed for negligence if the patient is not totally cured. Certain conditions must be
satisfied before liability can be considered. The person who is accused must have committed an act
of omission or commission; this act must have been in breach of the person’s duty; and this must
have caused harm to the injured person. The complainant must prove the allegation against the
doctor by citing the best evidence available in medical science and by presenting expert opinion.

CRIMINAL LIABILITY AND NEGLIGENCE

Indian Penal Code 1860 sections 52, 80, 81, 83, 88, 90, 91, 92 304-A, 337 and 338 contain the law of
medical malpractice in India.

A physician can be charged with criminal negligence when a patient dies from the effects of
anaesthesia during, an operation or other kind of treatment, if it can be proved that the death was the
result of malicious intention, or gross negligence. Before the administration of anaesthesia or
performance of an operation, the medical man is expected to follow the accepted precautions. In such
cases, the physician should be able to prove that he used reasonable and ordinary care in the
treatment of his patient to the best of his judgment. He is, however, not liable for an error judgment.
The law expects a duly qualified physician to use that degree of skill and care which an average man
of his qualifications ought to have, and does not expect him to bring the highest possible degree of
skill in the treatment of his patients, or to be able to guarantee cures. “Gross Lack of competency or
gross inattention, or wanton indifference to the patient’s safety, which may arise from gross
ignorance of the science of medicine and surgery or through gross negligence, either in the
application and selection of remedies, lack of proper skill in the use of instruments and failure to give
proper attention to the patient.”

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 WHEN DOES THE LIABILITY ARISE IN CASE OF MEDICAL
NEGLIGENCE?

The liability of a doctor arises not when the patient suffers injury but when the injury results due to
the conduct of the doctor, which was below reasonable care. Hence once there exist a duty which
must be established by the patient, then the next step is to prove breach of such duty and the
causation. Normally the liability arises only when the plaintiff can discharge the burden on him of
proving negligence. However, in some cases the principle of “res ipsa loquitor” which means the
thing speaks for it might come into action. Mostly the doctor is liable only for his own acts.
However, in some cases a doctor can also be made vicariously liable for the acts of another. The
example of such a situation is when a junior doctor assisting the senior doctor commits a mistake it
becomes the duty of the senior to have supervised him hence vicariously liable.

PROOF OF MEDICAL NEGLIGENCE

It has been held in different judgments by the National Commission and the Hon’ble Supreme Court
that a charge of professional negligence against a doctor stood on a different footing from a charge of
negligence against a driver of a vehicle. The burden of proof is correspondingly greater on the person
who alleges negligence against a doctor. It is known fact that things can go wrong even with the best
doctor. And the guilt or the negligence should be established beyond all reasonable doubts that his
skill fell below reasonable care that he ought to take during the treatment/ surgery.

STEPS / PROCEDURE TO FILE COMPLAINT PERTAINING TO MEDICAL

NEGLIGENCE

Medicine is a noble profession and practitioner must bring to his task a reasonable degree of skill and
knowledge and must exercise reasonable degree of care. Neither the very highest nor a very low
degree of care and competence, judged in the light of the circumstances of each case, is that the law
requires.

1. Damage to organ due to negligence.

2. Wrong treatment due to wrong diagnosis.

3. Money receipt or prescription or discharge summary or test reports when not provided.
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4. When treatment not chosen as accepted and established in medical norms /as per medical
research/available medical literature.

5. Theory of res ipsa loquitur [a thing speaks of itself] – in case any instrument left in the body, a
wrong part removed, allopathic treatment given by a homeopathic doctor etc.

6. Government Hospital liable if contribution from the employee’s salary deducted OR Payment
made by insurance company.

7. Negligent if these steps necessary are not observed by the medical practitioners. First – To decide
whether he must take up the case or not: Then- Whether the treatment given as per the diagnosis
made.

8. Hospital can also be negligent if „it is a case of nonavailability of oxygen cylinder either because
of the hospital having failed to keep available a gas cylinder or because of the gas cylinder being
found empty.

Medical negligence, now days have become one of the serious issues in India. The medical
profession is governed by legislation and by a code of ethics and etiquette. Negligence is defined as
absence of reasonable care and skill or wilful negligence of a medical practitioner in the treatment of
a patient which cause bodily injury or death of the patient. Our experience tells us that medical
profession, one of the noblest professions, is not immune to negligence which at times results in
death of patient or complete/partial impairment of limbs or culminates into another misery. There are
instances wherein most incompetent or ill- or under-educated doctors, on their volition, have made
prey the innocent patients. The magnitude of negligence or deliberate conduct of the medical
professionals has many times led to litigation. It was found that the awareness about medical
negligence among the medical as well as surgical specialists was unsatisfactory.
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CASE STUDIES ON MEDICAL NEGLIGENCE

Jacob Mathew v. State of Punjab

Brief Facts of the Case: A patient named Jiwan Lal was admitted to a private ward in CMC
Hospital, Ludhiana. At 11 pm of the date 22-02-1995, the patient suddenly had difficulty in
breathing. His elder son, Vijay Sharma called the nurse and doctor after seeing his father’s condition.
No doctor turned up for about 20-25 minutes. After that, Dr. Jacob Mathew and Dr. Allen Joseph
came to the room for the patient. The patient was immediately connected with an oxygen cylinder to
his mouth but the problem increased nevertheless. Apparently, the oxygen cylinder was found to be
empty and no other oxygen cylinder was available. Vijay Sharma went to the adjoining room and
brought another gas cylinder. In the midst of this, around 5-7 minutes were wasted. During this, the
doctor confirmed that the patient is dead. The younger son, Ashok Kumar Sharma filed a First
Information Report (FIR) under Section 304A read with Section 34 of the IPC.

(Section 304A of IPC- Causing death by negligence.)

(Section 34 of IPC- Common intention for criminal activity, all people included to be held liable)

Procedural History: According to Dr. Jacob Mathew, the patient was already suffering from the
advanced staged of cancer. The family was consulted to keep the patient at their home and given
proper nursing and solace. But the sons, being some influential persons having occupied position in
Government, requested the hospital to keep the patient under their care. Although the given advice,
the patient was admitted to the hospital.

Issues:
(1) Is there a difference between civil and criminal law in the concept of Negligence?
(2) Is there a test to determine the negligence level through which it will be decided whether
the doctor is held liable for the negligence or not?

Arguments raised by the Petitioner:

No professional doctor would try to hurt their patient as it is their responsibility to cure and heal the
patient as their reputation is on stake. A single failure may cost them a huge impact on their career.
Even in civil jurisdiction, the rule of res ipsa loquitur (the matter speaks for itself) is not of universal
application and has to be applied with extreme care and caution to the cases of professional
negligence and in particular that of the doctors.

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A medical practitioner takes full responsibility of the patient and hence does not gain anything out
of the negligence or the omission caused. If so, the practitioner is charged with criminal charges.
Accidents that happened during the course are unintentional and unforeseen.

Judgment:
Reverting back to the facts of the case before us, we are satisfied that all the averments made in the
complaint, even if held to be proved, do not make out a case of criminal rashness or negligence on
the part of accused-appellant. It is not the case of the complainant that the accused-appellant was not
a doctor qualified to treat the patient whom he agreed to treat. It is a cause of non-availability of
oxygen cylinder either because of the hospital having failed to keep available a gas cylinder or
because of the gas cylinder being found empty. Then, probably the hospital may be liable in civil law
(or may not be
– we express no opinion thereon) but the accused-appellant cannot be proceeded against under
Section 304-A of IPC on the parameters of Bolam’s test.

(Bolam’s Test: It is the test carried out to determine whether a doctor or a medical practitioner has
breached his duty regarding the care of the patient. The Bolam Test was established from the case of
Bolam v Friern Hospital Management Committee, 1957).

Dr. Ravishankar vs. Jery K. Thomas and Anr, II

Brief Facts of the Case: The complainant was having some nasal and breathing problems. He
approached the appellant doctor who upon examination advised a septoplasty, which was carried out
on August 18, 1999 in second Respondent's hospital. It is the case of the complainant that after the
operation, the pain aggravated, and the breathing problem persisted. After examination, the
complainant was advised to take some antibiotics for major nasal infection. Despite taking these
medicines, the complainant was not getting any relief, so he was taken to St. John's Hospital. A
computed tomography (CT) scan showed that there was a deposit inside the nasal cavity for which an
endoscopy was performed at St. John's hospital. Cotton gauze was removed from the nasal section on
November 28, 2000. It was in these circumstances alleging medical negligence on the part of
appellant and second respondent a complaint was filed before the State Commission. After hearing
perusal of evidence and other material on record, the State Commission held the second respondent
guilty of medical negligence and directed him to pay a compensation of Rs. 1 lac with interest @ 6%
p.a from the date of complaint along with the cost of Rs. 5000/-. Aggrieved by this order, the
Appellant doctor filed this appeal.

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Judgment:

As held by the State Commission, it is neither the surgery nor the procedure adopted that is under
challenge. What is being challenged is the leaving behind of cotton gauze after surgery and the non-
removal of it by the appellant doctor. After going through the record maintained at St. John's
hospital, Dr. Balasubramanian opined that after the CT scan a soft tissue mass (gauze piece) was
found retained in the right nasal cavity that was removed under local anaesthesia.

The National Commission confirmed the order and observed that it has no option but to deduce that
it was a clear case of medical negligence on the part of the appellant. The National Commission in
the case of Dr. Ravishankar vs. Jery K. Thomas and Anr, II (2006) CPJ 138 (NC) held that based on
the facts and circumstances, the obvious deduction is that the appellant doctor is responsible for
leaving behind ribbon gauze resulting in complications. Medical negligence was proved.

Dr. Kunal Saha vs Dr. Sukumar Mukherjee

landmark judgment in medical negligence cases and the first judgment that comes into our mind with
the highest amount of compensation granted till date is Dr. Kunal Saha Represented By Sri … vs
Dr. Sukumar Mukherjee And Ors. Which is famous as the Anuradha Saha Case. In this case, the
wife was suffering from drug allergy and the doctors were negligent in prescribing appropriate
medicines for the same which ultimately aggravated her condition and led to the death of the patient.
The court held the doctor liable for medical negligence and awarded compensation amounting to Rs.
6.08 crore.

V. Kishan Rao vs Nikhil Super Speciality Hospital

In the case of V.Kishan Rao Vs Nikhil Super Speciality Hospital, where a lady who was to
undergo the treatment for malaria fever was treated differently. An officer in the Malaria Department
filed a suit against the hospital authorities for performing the treatment of his wife negligently, who
was undergoing the treatment for typhoid fever instead of malaria fever. The husband got the
compensation of Rs 2 lakhs and in this case, the principle of res Ipsa loquitor was applied.

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Jacob Mathew vs State of Punjab & Anr

In Jacob Mathew .V. State of Punjab, the Supreme Court held that in some cases doctors are bound
to take make difficult choices. Sometimes situations make them go for things involving greater risk
because of higher chances of success in taking that decision. And there are some cases in which there
is lesser risk involved and higher chances of failure. So, the decision will depend upon the facts and
circumstances of the case.

Juggan Khan v. State of Madhya Pradesh

In Juggan Khan v. State of Madhya Pradesh, the appellant who was a registered Homoeopathic
medical practitioner. After seeing an advertisement, a woman went to him for the treatment of guinea
worms. After taking the medicine prescribed by him, she started feeling restless and even after the
administration of some antidotes, she died in the evening. The appellant was convicted for murder
under Section 302 of the IPC. The court held that it was a negligent act to prescribe poisonous
medicines without proper checking and knowledge of the same.

A.S. Mittal and another V State of UP and Others

In A.S. Mittal and another V State of UP and Others, the Apex Court dealt with the case of a
mishap in an ‘Eye Camp’ in Uttar Pradesh. In the camp, about 108 patients were operated out of
which 88 underwent cataract surgery. Out of all these people 84 suffered permanent damage to the
eyesight. It was found that this mishap was due to normal saline which was used in the operations.
The court held the doctor liable as this amounts to medical negligence. A PIL was filed in this case
under Article 32 of the Constitution.

Poonam Verma v Ashwin Patel and others

In the case of Poonam Verma v Ashwin Patel and others, the respondent had a diploma degree in
Homoeopathic Medicine and he administered some allopathic drugs to a patient who was suffering
from high fever. Subsequently, the patient was shifted to a nursing home where he died. The court
held the respondent liable as he was registered for providing Homoeopathic treatment but not under
the Allopathy system and his actions amounted to medical negligence. The Supreme court has also
defined the term “Medical Negligence”.

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Spring Meadows Hospital and another v Harjol Ahluwalia

In Spring Meadows Hospital and another v Harjol Ahluwalia, a child who was suffering from
typhoid was admitted to the appellant’s hospital. The nurse gave an injection to the child after that he
collapsed. After taking all the possible steps the child was shifted to AIIMS. The doctors there
informed the parents about the critical condition of the child. The child had a cardiac arrest because
of the overdose injection that was given to him. The court held the doctor and the nurse liable to
compensate for this negligence.

What does not amount to medical negligence?

If a patient has suffered an injury the doctor might not be held liable for negligence. In case of error
of judgement by the doctor, he shall not be charged against any such actions. Even doctors are
humans and, hence are prone to make mistakes, and therefore, they shall be allowed some relief.
Merely based on the fact that the decision of the doctor did not turn out to be favourable, he cannot
be held against such error in judgement. The Courts have observed that merely because the doctor
choose a different procedure/ treatment to cure the problem and it did not work as expected, will not
make him liable. One must prove that there was breach of duty on his part. A doctor performing his
duty with due care and caution could not be held liable for negligence. However, where error in
judgement was due to a negligent act, it shall then be termed breach of duty and the doctor shall be
held liable for his actions.

Duty of Care

The Hon’ble Supreme Court in Dr. Laxman Balkrishna Joshi Vs. Dr. Trimbak Bapu Godbole
had observed that every doctor must exercise reasonable “standard of care” that are set out in the
profession. Any breach towards these duties shall hold him liable for medical negligence.

The National Consumer Disputes Redressal Commission in Chandigarh Clinical Laboratory vs

Jagjeet Kaur upheld the findings of the District and State commission wherein the appellant was
directed to pay the complainant a compensation of Rs.25,000 along with cost of Rs. 2,000. The
appellant laboratory had issued the patient with wrong reports for which the Hon’ble Commission
held that the appellant had “duty of care” to give accurate findings to the patient and failure of the
appellant to take due care shall amount to medical negligence.
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 When does the liability arise?

A medical professional or hospital shall be held liable for all actions against the patients where they
have not taken proper standard of care and it has resulted in suffering on part of the patient. The
burden of proof shall lie on the complainant to prove a case of negligence. They must first establish
that there was a duty of care on part of the accused and that, there was breach of such duty.

The State Consumer Disputes Redressal Commission of Jharkhand in Jagdish Prasad Singh v. Dr.
A.K.Chatterjee directed the opposite party to pay a sum of Rs. 25,000 to the complainant as
compensation for his mental agony and physical harassment and Rs. 5,000 as litigation cost. It was
observed that the accused had failed to take due care to return the precise findings in the reports.
Whether harm came to the patient or not would not be the criteria for case against negligence.

However, in some case the courts use the principle of “ipsa loquitur” which means things speak for
itself. In such a scenario, it is presumed that the medical professional has acted beneath the set
standard of care causing negligence. Under this principle it is presumed that the injury could not have
been caused from anything but the negligence on part of the medical professional. In practice, the use
of this principle by the judge would mean that the negligence has already ensued. Here the burden
shifts onto the doctor to prove the case otherwise. Few examples are leaving an object inside the
patient’s body or operating the wrong patient.

Remedies- Medical Negligence

 Medical Council of India

An aggrieved party can file a complaint of negligence against a medical practitioner to the concerned
State Medical Council as they have the power to take action against the concerned doctor by
suspending or cancelling his registration. However, the Indian Medical Council Act, 1956 does not
give them the power to compensate the aggrieved party.

The accused is required to file a complaint to the council precisely specifying all the facts and
relevant details in the concerned matter. The council shall then allow the accused 30 days’ time to
submit his reply. If the council is not satisfied with the reply then they shall call upon both the parties
to present evidence in support of their claims.

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  Civil liability under Consumer Forum

An aggrieved person can approach the consumer courts to file a case against the accused person and
the hospital. In Indian Medical Association vs. V.P. Santha the Hon’ble Supreme Court observed
that the medical practitioners are covered under the Consumer Protection Act, 1986 and the medical
services rendered by them should be treated as services under section 2(1) (o) of the Consumer
Protection Act, 1986. Similarly, under the new Consumer Protection Act, 2019, the medical services
shall fall under the ambit of services as mentioned in section 2(42) of the new Act. Any matter in
medical negligence on the part of the service provider will be considered as deficiency under section
42(11) of the new Consumer Protection Act, 2019.

Any aggrieved person can claim damages for medical negligence against a doctor or a hospital.
Section 69(1) of the Consumer Protection Act, 2019 lays down the time limit within which a
complaint for medical negligence must be filed as 2 years from the date of injury.

 Criminal liability

Under various provisions of Indian Penal Code, 1860 any person who acts negligently or rashly that
results in threat to human life or personal safety or results in death of a person then the person shall
be punished with imprisonment and/or fine. However, the court have observed that in a matter of
negligence where a criminal case is being perused, the element of “mens rea” must be shown to exist.
To check for criminal liability, it must be clearly shown that the accused did something or failed to
do something which in the given circumstances no other medical professional in his ordinary senses
and prudence would have done or failed to do.

The aggrieved party will first file a complaint with the local police authority against the concerned
person/persons. If no action is taken, the aggrieved party can file a criminal complaint under
Criminal Procedure Code, 1973.

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 CONCLUSION

Though the doctors are seen as God and patients believe that they will get better after the treatment
and that they would be healed by the treatment provided. But sometimes it so happens that even the
doctors make mistakes which cost a lot to the patients in so many ways. Also, in some instances the
mistakes made by them are so dangerous that the patient has to face problems and undergo immense
sufferings.

The usage of equipment and medical tools in health care sector should be made with due care and
caution as it can lead to an injury to the consumer which may further result in the filing of a
complaint against the doctors and the other authorities involved. Yet, there is no provision which can
make the manufacturers of such unfit equipment liable for the damages.

Another important concern is that the services which are rendered free of charge are excluded from
the scope of the Consumer Protection Act, 1986. This creates a problem for patients who suffer
damages.

People are losing faith in the medical profession due to some serious medical negligence cases which
have made them disabled for their remaining lives. Some serious introspection and analysis are
required to be done for the Medical profession. It has utterly failed in self-governance. The medical
ethics need to be reformed and developed so as to serve with complete righteousness.

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 BIBLIOGRAPHY

 SCC Online.

 ipleaders.in

 legalbites.in

 wikipedia.org

 https://www.india.gov.in

 legalservicesindia.com

 indiankanoon.org

 prsindia.org

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