Supreme Court Awards Compensation in Medical Negligence Case: Doctor Held Liable for Patient's Vision Loss

The Supreme Court of India, in its judgment dated January 29, 2024, ruled in favor of 84-year-old P.C. Jain, awarding him compensation for the loss of vision in his left eye due to medical negligence by Dr. R.P. Singh. The Court upheld the decision of the National Consumer Disputes Redressal Commission (NCDRC) and reinstated the original compensation amount with 12% interest per annum, rejecting the doctor’s appeal.

Background of the Case

The case involved a prolonged legal battle between the complainant, P.C. Jain, and the accused doctor, R.P. Singh. Jain had undergone an eye surgery in 2002-2003, which allegedly resulted in the loss of vision in his left eye due to negligence. He filed a consumer complaint (No. 115 of 2005) before the District Consumer Disputes Redressal Commission (DCDRC), Faridabad, seeking compensation.

On April 4, 2008, the DCDRC ruled in favor of Jain, holding the doctor guilty of medical negligence and awarding ₹2 lakhs in compensation with 12% interest per annum. However, Dr. Singh appealed to the State Consumer Disputes Redressal Commission (SCDRC), which overturned the decision on May 23, 2011, citing lack of jurisdiction, and ordered the refund of the amount.

Jain challenged this decision before the NCDRC, which on July 29, 2016, remanded the case back to the SCDRC for a fresh hearing. However, the SCDRC again ruled in favor of Dr. Singh on July 6, 2017, dismissing Jain’s complaint. Unrelenting, Jain again approached the NCDRC, which on May 18, 2022, reinstated the compensation order of ₹2 lakhs but reduced the interest rate from 12% to 6% per annum.

Following this, Dr. Singh filed a review petition, falsely claiming that he had already paid the compensation amount. The NCDRC accepted this claim ex-parte on July 22, 2022, further limiting the interest to the period until September 5, 2008. Jain contested this review order, but his petition was rejected on September 26, 2022. This led to the present appeals before the Supreme Court.

Key Legal Issues

Whether Dr. R.P. Singh was guilty of medical negligence.
Whether the compensation awarded by the DCDRC was justified.
Whether the NCDRC erred in reducing the interest rate and accepting the doctor’s false claims.
Whether the Supreme Court should restore the original compensation order with interest.

Petitioner’s Arguments (P.C. Jain)

Jain’s counsel contended that:

Dr. Singh’s medical negligence was evident, as affirmed by multiple consumer forums and the Medical Council of India (MCI).
The MCI had already held Dr. Singh guilty of professional misconduct and removed his name from the Indian Medical Register for six months in 2015.
The NCDRC’s decision to reduce the interest rate was arbitrary and unjustified.
The review petition was accepted ex-parte based on false representations by Dr. Singh that he had paid the compensation amount.

Respondent’s Arguments (Dr. R.P. Singh)

Dr. Singh’s counsel argued that:

The allegations of negligence were unsubstantiated and lacked direct evidence.
The SCDRC had twice ruled in his favor, indicating the weakness of Jain’s claims.
The compensation amount had already been deposited and paid, and therefore, the interest should be limited.
The NCDRC had rightly reduced the interest rate to 6% considering the prolonged litigation.

Supreme Court’s Observations

The Supreme Court examined the evidence and found multiple inconsistencies in Dr. Singh’s defense.

1. Medical Negligence Proven

“The Ethics Committee of the Medical Council of India, after conducting an enquiry, held Dr. R.P. Singh guilty of professional misconduct and medical negligence, leading to the removal of his name from the Indian Medical Register for six months.”

The Court noted that this finding, which was never challenged by Dr. Singh, established his negligence beyond doubt.

2. Unjustified Reduction of Interest Rate

“The NCDRC’s reduction of interest from 12% to 6% was made without any proper reasoning. Given that Jain had been fighting for compensation for over 20 years, this reduction was arbitrary.”

The Court restored the original 12% interest rate awarded by the DCDRC.

3. False Representation by Dr. Singh

“The review petition was accepted ex-parte based on a misrepresentation that the compensation had been paid. The complainant’s assertion that he never received any payment stands unchallenged.”

The Court imposed a fine of ₹50,000 on Dr. Singh for misleading the NCDRC.

Final Judgment

The Supreme Court ruled in favor of Jain and restored the original compensation order. The Court directed:

“The respondent, Dr. R.P. Singh, shall pay compensation of ₹2 lakhs with interest at 12% per annum from the date of filing the complaint until actual payment is made.”

The Court further warned:

“If the payment is not made within two months, the interest rate shall increase to 15% per annum.”

Additionally, the Court imposed a ₹50,000 cost on Dr. Singh for misleading the NCDRC.

Key Takeaways from the Judgment

Medical negligence claims require strong evidence, and findings by professional bodies like the MCI carry significant weight.
Consumer protection forums must ensure that interest on compensation is just and fair, especially in long-drawn cases.
False representations in legal proceedings can attract penalties, as seen in the ₹50,000 cost imposed on Dr. Singh.
The Supreme Court prioritizes justice for victims of medical negligence and upholds their right to fair compensation.

This landmark ruling reinforces consumer rights and highlights the judiciary’s commitment to holding negligent medical practitioners accountable.

Petitioner Name: P.C. Jain.
Respondent Name: Dr. R.P. Singh.
Judgment By: Justice B.R. Gavai, Justice Sandeep Mehta.
Place Of Incident: Faridabad, Haryana.
Judgment Date: 29-01-2024.

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