Medical Negligence Must Be Proven Within Pleadings — Courts Cannot Build a New Case for the Complainant: Supreme Court Overturns Rs 20 Lakh Compensation in Maternal Death Case

“It is well settled that the decision of a case cannot be based on grounds outside the pleadings” — Supreme Court of India set aside orders passed by the State and National Consumer Disputes Redressal Commissions, which had held a doctor guilty of medical negligence and imposed ₹20.26 lakhs in compensation.

The Supreme Court ruled that the National Commission had “clearly transgressed its jurisdiction” by building a new case for the complainants — one not even pleaded in the original complaint — thereby violating settled principles of civil jurisprudence.

A Tragedy Turns Into a Twelve-Year Litigation

The case arose from a tragic incident on December 22, 2005, where Charanpreet Kaur, wife of Manmeet Singh Mattewal, died hours after delivering a stillborn child at Deep Nursing Home, Chandigarh, under the care of Dr. (Mrs.) Kanwarjit Kochhar, the attending obstetrician.

The complainant alleged negligence during post-delivery care, particularly in arranging timely blood transfusion after postpartum haemorrhage (PPH), and sought ₹95.21 lakhs in compensation from the hospital, the doctor, and the insurer.

The State Consumer Disputes Redressal Commission (SCDRC) partially allowed the claim on January 31, 2007, awarding ₹20.26 lakhs in compensation, attributing the mother’s death to negligence but absolving the doctor for the child’s death.

Upon appeal, the National Commission (NCDRC) on May 9, 2012, held that no liability would attach to the Nursing Home but placed the entire compensation burden on Dr. Kochhar, finding fault with her antenatal care — a point that was never raised in the complaint.

Can a Court Find Negligence on Grounds Not Pleaded by the Complainant?

The core legal issue before the Supreme Court was whether the NCDRC erred in going beyond the pleadings to build a new case based on alleged antenatal negligence, when the original complaint had only alleged negligence after delivery.

The Court framed the issue as one of judicial overreach and procedural fairness, stressing that consumer fora, like civil courts, must confine their decisions to what is pleaded and proved.

Courts Cannot Manufacture a New Case

In a detailed judgment authored by Justice Sanjay Kumar, the Supreme Court observed:

“The NCDRC clearly transgressed its jurisdiction in building a new case for the complainants, contrary to their pleadings.”

“It is well settled that the decision of a case cannot be based on grounds outside the pleadings of the parties... and it is the case pleaded that has to be found.” — Ref: Trojan and Company v. Rm. N.N. Nagappa Chettiar (1953)

The Court also invoked Jacob Mathew v. State of Punjab (2005) and Martin F. D’Souza v. Mohd. Ishfaq (2009) to underscore that not every death or unsuccessful treatment amounts to medical negligence, and courts must defer to expert medical opinions.

Medical Evidence Overwhelmingly Favoured the Doctor

Crucially, the Court noted that five independent Medical Boards, all constituted on the complaint of the husband himself, unanimously found no gross medical negligence in the delivery or post-delivery management.

Even the report that left open the question of pre-existing anaemia or cardiac complications did not affirmatively conclude negligence.

Yet, the NCDRC, in the absence of expert support, ventured into new territory by criticising the doctor’s alleged failure to order routine haematological tests during antenatal care — a ground not raised by the complainants at all.

"Not for them to act as Medical Experts"

Calling out the tendency of consumer fora to substitute their own views in place of expert medical opinion, the Supreme Court noted:

“Consumer Fora are not experts in medical science and must not substitute their own views over that of specialists.”

It found that no evidence had been led to prove negligence in antenatal care, and more importantly, the complainants never alleged any such lapse.

Thus, the Court held that the entire foundation of the NCDRC’s judgment was alien to the pleadings and violative of the principle of fair trial.

Compensation Reversed, ₹10 Lakhs to Be Returned

The Supreme Court allowed the appeal and dismissed the original complaint, reversing both the NCDRC and SCDRC findings.

It ordered: “Manmeet Singh Mattewal shall return and refund the sum of ₹10,00,000 received by him, pursuant to the orders passed in this litigation... in monthly instalments of ₹1,00,000.”

Of this, ₹3,00,000 is to be paid to New India Assurance Co. Ltd., and ₹7,00,000 to Dr. Kanwarjit Kochhar and her husband, as the nursing home is no longer in existence.

A Landmark Ruling on Medical Negligence and Judicial Discipline

This decision stands as a significant reaffirmation of judicial discipline in the adjudication of consumer disputes. The Supreme Court has sent a clear message that courts cannot invent negligence where none was pleaded or proved, particularly in technical fields like medicine, where expert evidence is paramount.

The ruling will likely serve as a precedent for restraining lower consumer fora from exceeding their remit and misapplying principles of tortious liability in healthcare disputes.

Date of Decision: September 9, 2025