Supreme Court Clarifies Treatment Failure Alone Doesn’t Prove Negligence Sets Aside NCDRC Compensation Order

Bench Rules Lack of Patient Response Insufficient to Establish Medical Negligence

NCDRC Censured for Overstepping Pleadings, Patient Ordered to Refund Rs 10 Lakh

By Our Legal Correspondent

New Delhi: September 10, 2025: The Supreme Court on September 9, 2025 ruled that a doctor cannot be held automatically negligent merely because a patient did not improve after treatment or surgery failed. The Court set aside the National Consumer Disputes Redressal Commission’s (NCDRC) compensation order and emphasised that the doctrine of res ipsa loquitur does not apply without strong evidence of professional fault.

A two-judge bench of Justices Sanjay Kumar and Satish Chandra Sharma allowed an appeal by Deep Nursing Home and its doctors, quashing the NCDRC’s May 9, 2012 order and the State Consumer Disputes Redressal Commission’s (SCDRC) January 31, 2007 judgment. The bench directed the complainant, Manmeet Singh Mattewal, to refund Rs 10 lakh already paid under the impugned orders because the nursing home no longer existed and the compensation award could not stand.

“No favourable response to treatment does not, by itself, mean medical negligence,” the Court declared, noting that doctors do not intentionally harm patients and that a single treatment failure can damage a doctor’s reputation without proving professional fault.

The Court relied on its earlier judgments in Jacob Mathew v. State of Punjab (2005) and Martin F D’Souza v. Mohd Ishfaq (2009) to underline that medical outcomes can vary despite reasonable care. It stressed that courts and consumer forums lack medical expertise and must not substitute their own views for those of qualified specialists unless there is clear proof of breach of duty and professional standard.

In the underlying dispute, Mattewal’s wife, Charanpreet Kaur, a lecturer at the Punjab Institute of Cooperative Training, and their newborn son both died soon after delivery at Deep Nursing Home in December 2005. The complainant alleged that the facility was ill-equipped, that Kaur’s blood group was not checked promptly, that blood transfusion was delayed, and that records were later fabricated to evade liability.

The SCDRC initially found negligence by the nursing home and Dr Kanwarjit Kochhar, the obstetrician-gynaecologist who conducted the delivery, and awarded Rs 20.26 lakh in compensation to Mattewal and his elder son. On appeal, the NCDRC absolved the nursing home but still placed the full Rs 20.26 lakh liability on Dr Kochhar, despite the original complaint being limited to post-delivery care issues.

The Supreme Court noted that the NCDRC reserved its judgment on July 27, 2010 but pronounced it nearly two years later on May 9, 2012. This delay underscored the need for prompt adjudication in consumer disputes, especially those involving life-and-death outcomes.

Medical boards convened at Mattewal’s request produced five expert reports. All but one absolved Dr Kochhar of any negligence, with the lone dissent noting insufficient data to determine if a pre-existing condition contributed to Kaur’s death. The bench held that Mattewal could not reject the favourable conclusions of experts he himself engaged.

The apex court criticised the NCDRC for exceeding its jurisdiction by inventing a case of antenatal negligence against Dr Kochhar—a claim never pleaded by the complainant. By building a new case, the forum acted beyond its mandate and transgressed procedural limits set for consumer disputes.

Upon finding no proven fault in Dr Kochhar’s conduct during delivery or post-delivery care, the Court dismissed the consumer complaint. It ordered Mattewal to refund the Rs 10 lakh he received under the NCDRC order to Dr G S Kochhar, and New India Assurance Company Limited, since the nursing home entity was defunct.

In its judgment, the Supreme Court reiterated that the principle of res ipsa loquitur applies only when negligence is self-evident and no other explanation exists. Mere treatment failure or a negative medical outcome does not automatically shift the burden to doctors to prove their innocence; rather, the complainant must produce strong evidence of a breach of standard care.

This ruling has wide implications for medical professionals and consumers alike. It protects doctors from harassment in consumer courts over treatment failures that reflect complex medical realities rather than professional lapses. At the same time, it upholds patients’ rights by requiring clear proof of negligence before awarding compensation.

Legal experts say consumer forums will now be more cautious in accepting compensation claims based solely on poor outcomes. Forums must stick to the pleadings and corroborate allegations with credible expert testimony before finding medical negligence.

The judgment also recognised that, despite some commercialization in healthcare, the entire medical fraternity cannot be branded incompetent due to a few “bad apples.” The Court urged balancing consumer protection with safeguarding medical expertise and professional integrity.

Commentators note that this decision aligns with evolving global standards where courts distinguish between adverse medical outcomes and true negligence. A similar approach in the United Kingdom and Australia has led to more nuanced consumer claims in healthcare, demanding robust proof rather than presumptions of fault.

By clarifying that treatment failure alone does not equate to negligence, the Supreme Court has set a high bar for consumer claims while reinforcing doctors’ confidence in providing care without fear of frivolous litigation. This judgment is likely to reduce the number of speculative medical negligence cases and promote fair adjudication based on expert evidence.

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