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Deep Nursing Home & Anr. vs Manmeet Singh Mattewal & Ors.

Not available · 2025 INSC 1094Decided 9 Sept 2025
Not available
Justice Sanjay Kumar · Justice Satish Chandra Sharma

Background

Manmeet Singh Mattewal lost his wife, Charanpreet Kaur, and newborn son within hours of each other during delivery at Deep Nursing Home, Chandigarh. He and his surviving son complained of medical negligence against the nursing home and the treating obstetrician, Dr. Kanwarjit Kochhar. The State Consumer Disputes Redressal Commission found the doctor negligent in the mother's treatment (though not for the infant's death) and awarded about ₹20.26 lakh, largely payable by the insurer. On appeal, the National Consumer Disputes Redressal Commission (NCDRC) upheld the finding of liability but on entirely new grounds not raised by either side.

Decision Breakdown

The Supreme Court held that the NCDRC had exceeded its jurisdiction by effectively building a new case for the complainants based on grounds and evidence never pleaded or argued by them, which is impermissible: a party is entitled to know and meet the actual case against it. Since multiple independent medical boards had found no negligence in the delivery and post-delivery treatment, and that finding had attained finality (no separate appeal was filed against it by the complainants), the entire consumer complaint could not survive on a case invented afterward by the NCDRC. The Court set aside the NCDRC's and the State Commission's orders and dismissed the original complaint, while directing the complainant to refund the compensation amount already received, in instalments, to the doctor and the insurance company.

Lesson Learnt

In legal proceedings, a decision-making body (court, tribunal, or consumer commission) cannot decide a case on a theory or ground that was never argued or put to the other side, doing so denies a fair chance to respond, and such a decision cannot stand even if the underlying tragedy is a genuine one.

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

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