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Ashish Kumar Mazumdar v. Aishi Ram Batra Charitable Hospital Trust

Civil Appeal · Neutral citation not assigned (Civil Appeal No. 4010 of 2010)Decided 22 Apr 2014
Civil Appeal No. 4010 of 2010
Chief Justice P. Sathasivam · Justice Ranjan Gogoi · Justice N.V. Ramana

Background

A hospital inpatient with high fever and delirium went missing from his room at night and was found seriously injured elsewhere in the premises. The injuries left him paralysed below the waist. The High Court held the hospital negligent and awarded Rs.11 lakh with 12% interest; both the patient and hospital appealed.

Decision Breakdown

The Supreme Court dismissed both sets of appeals and retained the award. A hospital's duty extended beyond diagnosis and treatment to reasonable safety and supervision of vulnerable inpatients. On the proven circumstances, the courts could infer negligence requiring an explanation, and the hospital had not displaced that conclusion. The concurrent findings were sound, and the damages for career prospects, attendant needs and non-financial suffering were neither inappropriate nor inadequate enough to warrant further intervention.

Lesson Learnt

Hospitals must take reasonable steps to protect patients whose condition makes them vulnerable, as well as provide treatment. An inference of negligence still depends on the proved circumstances; an unexplained injury is not automatically liability in every case.

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

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