Supreme Court Imposes Costs on Doctor for False Representation in Medical Negligence Case, Upholds 12% Interest on Compensation

In a recent judgment, the Supreme Court of India has reinforced the principles of justice and accountability in cases of medical negligence. The apex court, in its decision dated 29th January 2024, upheld the compensation awarded to the appellant, P.C. Jain, who suffered loss of vision due to alleged medical negligence by respondent Dr. R.P. Singh. The court, led by Justices B.R. Gavai and Sandeep Mehta, modified the National Consumer Disputes Redressal Commission's (NCDRC) order by reinstating the 12% interest rate on the compensation and additionally imposed costs on the respondent for false representation.

The case, which revolved around a surgical procedure conducted by Dr. Singh that resulted in the appellant losing vision in his left eye, saw multiple legal challenges, including issues of jurisdiction and the quantum of compensation. Initially, the District Consumer Disputes Redressal Commission, Faridabad, granted compensation to Jain, which was later challenged on jurisdictional grounds.

The Supreme Court observed, "In the background of the aforesaid facts, the issue regarding the respondent Dr. R.P. Singh having committed medical negligence in treating the appellant-complainant P.C. Jain is no longer res integra," thus affirming the findings of medical negligence.

Addressing the long-drawn litigation and the suffering of the appellant, the court stated, "The appellant-complainant P.C. Jain who is 84 years of age as on date claims to have suffered loss of vision in the left eye owing to the gross medical negligence committed by respondent-Dr. R.P. Singh in a surgical procedure which was undertaken way back in the year 2002-2003. He has been contesting this long drawn out litigation for a rightful claim of compensation for more than 20 years."

Further, the court harshly criticized the conduct of Dr. Singh, who had misrepresented facts to the NCDRC. "As the respondent Dr. R.P. Singh procured the order under review dated 22nd July, 2022 by making a false representation that the amount of compensation had been paid to the appellant-complainant P.C. Jain, we impose a cost of Rs. 50,000/- upon the respondent Dr. R.P. Singh," read the judgment.

Date of Decision: 29th January 2024

P.C. Jain VS Dr. R.P. Singh