Supreme Court Reduces Compensation in Medical Negligence Case

Medical negligence cases are among the most complex legal disputes, as they involve the delicate balance between patient rights and medical professionals’ accountability. In the case of Chandigarh Nursing Home and Anr. v. Sukhdeep Kaur, the Supreme Court was called upon to determine whether the National Consumer Disputes Redressal Commission (NCDRC) was justified in increasing the compensation beyond the amount sought by the complainant. The Court ruled in favor of the appellants, reducing the compensation from ₹10 lakhs to ₹4 lakhs.

Background of the Case

The case arose when the respondent, Sukhdeep Kaur, a minor, filed a consumer complaint through her father, alleging medical negligence against Chandigarh Nursing Home. She claimed that she was given an incorrect diagnosis and treatment by an Ayurvedic doctor who was not qualified to prescribe allopathic medicines. The incorrect treatment led to severe rashes that became uncontrollable.

Legal Proceedings

1. District Consumer Disputes Redressal Forum

On March 11, 2010, the District Forum held that there was negligence on the part of the appellants.
It awarded ₹1 lakh in compensation along with interest at 9% per annum.

2. State Consumer Disputes Redressal Commission

The appellants challenged the District Forum’s order before the State Commission, Punjab.
The State Commission dismissed the appeal and imposed additional costs of ₹10,000.

3. National Consumer Disputes Redressal Commission (NCDRC)

The appellants filed a revision petition before the NCDRC.
The NCDRC not only upheld the findings of the lower forums but also enhanced the compensation from ₹1 lakh to ₹10 lakhs.
This increase in compensation was challenged by the appellants before the Supreme Court.

Arguments by the Petitioner (Chandigarh Nursing Home)

The appellants argued that:

The NCDRC had no authority to enhance the compensation in a revision petition filed by the appellants.
The original complainant had not filed any appeal seeking higher compensation.
The increase from ₹1 lakh to ₹10 lakhs was arbitrary and not supported by any assessment of disability or suffering.
The NCDRC’s reliance on other cases to determine compensation was misplaced, as compensation must vary based on the facts of each case.

Arguments by the Respondent (Sukhdeep Kaur)

The respondent countered that:

The National Commission had suo motu revisional powers under Section 21(b) of the Consumer Protection Act, 1986, allowing it to enhance compensation.
Despite not filing an appeal, the complainant was entitled to higher compensation given her suffering.
Even today, she has not completely recovered from the incorrect treatment, and additional compensation is justified.

Supreme Court’s Observations

The Supreme Court, comprising Justices M.R. Shah and Krishna Murari, analyzed the legal principles governing compensation in consumer disputes and made the following key observations:

1. NCDRC Lacked Authority to Enhance Compensation

The Court noted that the original complainant had never challenged the ₹1 lakh compensation awarded by the District Forum. Since only the appellants had challenged the decision, the NCDRC had no jurisdiction to enhance the compensation in their revision petition. The judgment stated:

“At the most, the National Commission could have dismissed the revision application unless it specifically exercised suo motu revisional power under Section 21(b) of the Consumer Protection Act.”

2. No Justification for ₹10 Lakhs Compensation

The Court found that while negligence was proven, the NCDRC failed to assess the severity of suffering or disability while increasing the compensation. The ruling emphasized:

“The amount of compensation varies from person to person, looking at the damages and disability suffered. Merely because in some cases the amount was enhanced, it cannot be automatically applied to others.”

3. Reduction of Compensation to ₹4 Lakhs

Considering the complainant’s prolonged suffering and treatment, the Supreme Court held that the compensation should be increased from ₹1 lakh to ₹4 lakhs, rather than ₹10 lakhs.

Final Judgment

The Supreme Court ruled:

The NCDRC’s order enhancing the compensation to ₹10 lakhs was quashed.
The appellants were directed to pay ₹4 lakhs instead of ₹1 lakh.
The balance amount must be paid within six weeks; failing this, an interest rate of 7.5% would apply.
The complainant is permitted to withdraw any already deposited amount.

Key Takeaways from the Judgment

1. Limits on Revisional Powers of NCDRC

The ruling clarifies that consumer courts cannot increase compensation beyond what is requested unless they explicitly exercise suo motu powers and notify all parties in advance.

2. Compensation Must Be Proportional

The decision highlights that compensation should be based on the specific injury suffered, rather than being arbitrarily enhanced.

3. Protection Against Arbitrary Enhancements

This ruling provides relief to businesses and professionals facing consumer complaints, ensuring that higher forums do not impose excessive financial liabilities without a sound basis.

Conclusion

The Supreme Court’s decision in Chandigarh Nursing Home and Anr. v. Sukhdeep Kaur reaffirms key legal principles in medical negligence cases. It ensures that while victims of medical negligence receive fair compensation, the process remains just and reasonable. The ruling provides a crucial precedent for future consumer disputes and medical malpractice claims.

Petitioner Name: Chandigarh Nursing Home and Anr..
Respondent Name: Sukhdeep Kaur.
Judgment By: Justice M.R. Shah, Justice Krishna Murari.
Place Of Incident: Chandigarh.
Judgment Date: 09-09-2022.

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