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Narayana Health & Ors. v. The State of West Bengal & Ors.

Criminal Appeal · 2026 INSC 481Decided 12 May 2026
Crl.A. No.-002461-002462 - 2026
Justice Pamidighantam Sri Narasimha · Justice Alok Aradhe

Background

A patient was treated at Narayana Multispecialty Hospital, Barasat, Kolkata, for a fractured femur, and after discharge her son (the complainant) disputed certain billing charges, including a diagnostic test (HRCT, worth Rs. 2,500) that was billed but not actually performed. The hospital acknowledged the error, issued a revised bill, and offered to refund the amount, but the complainant instead filed a criminal complaint alleging cheating, criminal breach of trust and criminal conspiracy (Sections 406, 420, 120B IPC) plus an offence under West Bengal's clinical establishments regulation law, also alleging hospital staff behaved improperly and threatened him. A Magistrate issued summons against the hospital, its parent company, its Chairman, and a staff member. The High Court, instead of ruling on whether any criminal offence was actually made out, set aside the summoning order but remanded the matter for reconsideration while also making a passing remark that an offence appeared to have been committed.

Decision Breakdown

The Supreme Court held that even taking the complaint's allegations at face value, they did not disclose commission of any criminal offence, billing errors that were promptly corrected and refunded, without more, do not amount to cheating or criminal breach of trust. On the alleged delay in supplying medical records, the Court held this was, at most, a service deficiency remediable under the state's clinical establishments law (which provides for penalties and an adjudicating authority for such grievances), not a criminal offence, since the complaint failed to specify how the conduct met the threshold for criminal liability under that Act. The Court held the High Court had erred by not properly examining whether any offence was made out and by making an unwarranted observation that an offence had occurred without proper analysis. It exercised its inherent power under Section 482 CrPC to quash the criminal complaint entirely, while clarifying that the complainant remains free to pursue civil or statutory remedies (such as under the clinical establishments regulation regime) separately.

Lesson Learnt

A billing dispute or service grievance with a hospital, even one involving an acknowledged error, is ordinarily a civil or regulatory matter, not a criminal one; criminal proceedings under IPC offences like cheating require specific allegations showing dishonest intent, not just a disputed bill that was later corrected.

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

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