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ARUN KUMAR MANGLIK vs. CHIRAYU HEALTH AND MEDICARE PRIVATE LTD. & ANR.

SCR Citation: [2019] 3 S.C.R. 281
Year/Volume: 2019/ Volume 3
Date of Judgment: 09 January 2019
Petitioner: ARUN KUMAR MANGLIK
Disposal Nature: Appeal Allowed
Neutral Citation: 2019 INSC 43
Judgment Delivered by: Honble Dr. Justice D.Y. Chandrachud
Respondent: CHIRAYU HEALTH AND MEDICARE PRIVATE LTD. & ANR.
Case Type: CIVIL APPEAL /227/2019
Order/Judgment: Judgment
1. Headnote

Negligence:Medical Negligence – Complaint before Medical Council of India – Alleging medical negligence leading to death of the wife ofthe complainant – Medical Council found that treatment given was not timely and the Director of the Hospital and the other doctor,both were guilty of professional misconduct – The Council issued awarning to the doctors directing them to be more careful in future –Complaint before State Consumer Disputes Redressal Commission(SCDRC) seeking compensation of Rs. 48 lakhs – SCDRC held that medical negligence was established and awarded compensation of Rs.6 lakhs with interest @ 9% – National Consumer Disputes Redressal Commission (NCDRC) reversing the finding of SCDRC,rejected the claim of the complainant – On appeal, held: The medical treatment provided in the present case was not in accordance with WHO Guidelines as well as Guidelines prescribed by the Directorate of National Vector Borne Diseases Control Programme – Thus, the respondent-hospital failed to satisfy the standard of reasonable care as laid down in the *Bolam case – NCDRC without any cogent reason, reversed the findings of fact reached by SCDRC – However,since the Director of the hospital was not a treating doctor nor the referring doctor, hence cannot be held personally liable for medical negligence – The respondent-hospital is held liable for medical negligence – The compensation granted by SCDRC is also inadequate and hence it is enhanced to Rs. 15 lakhs with interest@ 9% – Consumer Protection Act, 1986.Medical Negligence – Ascertainment of – Held: A medical practitioner would be liable for medical negligence only where the conduct falls below the standards of a reasonably competent practitioner in the field – While adopting standard of care, Indian courts must be conscious of the fact that a large number of hospitals and medical units in the country, do not have access to latest technology and medical equipment – The threshold to prove unreasonableness is set with due regard to the risks associated with medical treatment and the conditions under which medical professionals function – Where unreasonableness in professional conduct has been proved, a professional cannot escape liability for medical evidence merely by relying on a body of professional opinion.Compensation:Compensation for the death of home-maker spouse who is not employed – Held: Contribution made by a non-working spouse to the welfare of the family has an economic equivalence – Therefore,for computing compensation payable for the death of a home-maker,the Court must bear in mind that the contribution is significant and capable of being measured in monetary terms.

2. Case referred
3. Act
  • Consumer Protection Act, 1986 (68 of 1986)
4. Keyword
  • Medical Negligence
  • Medical Council of India
  • Complaint
  • no timely treatment
  • professional misconduct
  • NCDRC
5. Equivalent citation
    Citation(s) 2019 (7) SCC 401 = 2019 (7) Suppl. SCC 401 = 2019 (5) JT 379 = 2019 (5) Suppl. JT 379 = 2019 (3) SCALE 333