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Mrs. Kalyani Rajan vs. Indraprastha Apollo Hospital & Ors.

Civil Appeal · 2023 INSC 921Decided 17 Oct 2023
Civil Appeal No. 10347 of 2010
A.S. Bopanna · Prashant Kumar Mishra

Background

The appellant's husband, aged 37, underwent neurosurgery at Indraprastha Apollo Hospital for a spinal cord condition (Chiari Malformation). After the operation he was shifted to a private room instead of the ICU, and later that night suffered a fatal cardiac arrest after complaining of neck pain, sweating and dizziness. His widow alleged medical negligence, claiming he should have been kept in the ICU and was not adequately monitored by the treating doctors after the surgery. The National Consumer Disputes Redressal Commission rejected her complaint, finding no proven medical negligence.

Decision Breakdown

The Supreme Court examined the hospital's records and found that the patient was seen by multiple doctors post-surgery, and that shifting him to a private room (rather than ICU) was standard practice for patients without post-operative complications: supported by data showing most such patients were not moved to the ICU. There was no evidence connecting the cardiac arrest to the surgery or to any lapse in post-operative care, especially since the patient had no prior history of heart disease. Relying on precedents including Jacob Mathew, Bombay Hospital, Martin F. D'Souza and Kusum Sharma, the Court reiterated that a doctor cannot be held negligent merely because a treatment fails or a patient dies, and that the principle of res ipsa loquitur (the thing speaks for itself) does not apply without strong evidence pointing to negligence. Finding no proof of negligence, the appeal was dismissed.

Lesson Learnt

In medical negligence cases, a patient's family must produce cogent evidence connecting the alleged lapse in care to the harm suffered: an unfortunate or unexpected death after surgery does not, by itself, prove that doctors or hospitals were negligent.

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

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