Medical Negligence and Compensation: Supreme Court’s Ruling in Arun Kumar Manglik Case

The Supreme Court of India recently delivered a crucial judgment in the case of Arun Kumar Manglik vs. Chirayu Health and Medicare Private Ltd., addressing the issue of medical negligence and its consequences. The case revolved around the unfortunate demise of Madhu Manglik, who was diagnosed with dengue fever and admitted to Chirayu Health and Medicare hospital in Bhopal, where she allegedly received inadequate treatment, leading to her untimely death.

Background of the Case

Madhu Manglik, wife of the appellant Arun Kumar Manglik, was admitted to the hospital on November 15, 2009, after being diagnosed with dengue fever. The medical reports indicated a critical condition with falling platelet counts. Despite this, the hospital staff allegedly failed to conduct timely monitoring and essential tests. By the evening of her admission, her condition worsened, leading to cardiac arrest and death by 8:50 PM.

Arun Kumar Manglik filed a complaint alleging medical negligence, seeking a compensation of Rs. 48 lakhs. The Madhya Pradesh State Consumer Disputes Redressal Commission (SCDRC) found the hospital guilty and awarded Rs. 6 lakhs in compensation. However, this verdict was overturned by the National Consumer Disputes Redressal Commission (NCDRC), prompting an appeal to the Supreme Court.

Key Arguments by the Petitioner

• The hospital failed to follow established medical protocols for dengue treatment.
• No proper monitoring of blood parameters, which could have detected the declining condition.
• Critical blood tests were delayed until the patient suffered cardiac arrest.
• The treating doctors neglected standard guidelines, including those from the World Health Organization (WHO).
• The hospital attempted to shift blame by arguing that the patient had consumed aspirin before admission, despite being informed of this fact.

Arguments by the Respondents

• The patient was in stable condition at the time of admission.
• Guidelines from the Directorate of National Vector Borne Diseases Control Programme did not require additional blood monitoring unless there were signs of dengue hemorrhagic fever.
• The hospital’s medical staff followed standard treatment procedures.
• The hospital could not be held responsible for pre-existing health complications.

Supreme Court’s Observations

The Supreme Court, led by Justice D.Y. Chandrachud and Justice Hemant Gupta, examined the case in detail and ruled that:

• The hospital failed to conduct timely monitoring of the patient’s vital parameters.
• Even after the patient’s condition deteriorated, essential tests were delayed until after cardiac arrest.
• There was a clear violation of WHO guidelines, which emphasize close monitoring of dengue patients with declining platelet counts.
• The NCDRC erred in overturning the SCDRC’s findings, which were based on evidence and expert medical opinions.

Important Judicial Remarks

The Supreme Court emphasized:

“The essential aspect of the case, which bears out the charge of medical negligence, is that between 7:30 AM and 6:00 PM, the course of treatment did not indicate any further monitoring of essential parameters, particularly those detectable through laboratory blood tests.”

The Court further observed:

“The failure to closely monitor the patient’s condition led to a situation where medical intervention came too late. Had appropriate steps been taken, the hospital could have recognized the declining condition and administered corrective treatment in time.”

Final Judgment

The Supreme Court held the hospital liable for medical negligence and overturned the NCDRC ruling. It increased the compensation to Rs. 15 lakhs, along with 9% interest per annum from the date of the original complaint.

Legal and Social Impact

This judgment sets a precedent in medical negligence cases, reinforcing the need for hospitals to adhere to strict monitoring guidelines, especially in critical conditions like dengue. It also emphasizes that failure to follow established medical protocols can lead to significant legal consequences.

Petitioner Name: Arun Kumar Manglik.
Respondent Name: Chirayu Health and Medicare Private Ltd. & Anr..
Judgment By: Justice D.Y. Chandrachud, Justice Hemant Gupta.
Place Of Incident: Bhopal.
Judgment Date: 09-01-2019.

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