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Arun Kumar Manglik v. Chirayu Health and Medicare Private Ltd. & Anr.

Civil Appeal · 2019 INSC 43Decided 9 Jan 2019
Civil Appeal Nos. 227-228 of 2019
Dr. Justice D.Y. Chandrachud · Justice Hemant Gupta

Background

The appellant's wife, aged 56, was admitted to a Bhopal hospital with dengue fever; despite being placed on intravenous fluids, her blood parameters were not monitored for roughly 11 hours even as her condition silently worsened, and she suffered cardiac arrest and died the same evening. A state consumer commission found the hospital negligent and awarded Rs. 6 lakh compensation, but the National Consumer Disputes Redressal Commission (NCDRC) reversed this finding on appeal, prompting the husband to approach the Supreme Court.

Decision Breakdown

The Supreme Court held that WHO and national guidelines for treating dengue patients required regular monitoring of blood parameters, which the hospital failed to do for most of the day despite the patient's known cardiac history: a lapse the Medical Council of India itself had flagged when it warned the treating doctors. Applying the established legal standard for medical negligence (the "Bolam test," as refined by Indian courts, which asks whether the doctor met the standard of a reasonably competent practitioner), the Court found the NCDRC had wrongly overturned the state commission's well-reasoned finding without adequate justification. It restored the finding of negligence against the hospital (though not against its director personally, since he wasn't the treating doctor) and increased compensation from Rs. 6 lakh to Rs. 15 lakh, also recognizing that a non-working spouse's contribution to the family has real economic value.

Lesson Learnt

Hospitals and doctors are legally required to monitor patients according to accepted medical guidelines, and failing to do so, even without any single dramatic error, can amount to actionable negligence; the law also increasingly values a homemaker spouse's unpaid contributions to a family in monetary terms when calculating compensation for their loss.

Official source (sci.gov.in)View Judgment (PDF)

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