The Supreme Court on Tuesday (22nd April, 2025) upheld the vicarious liability of Kamineni Hospitals in a medical negligence case, affirming the findings of the National Consumer Disputes Redressal Commission (NCDRC) that held the hospital accountable for the death of a 27-year-old patient following a surgery conducted by its staff doctor.
A Bench comprising Justice B.R. Gavai and Justice Augustine George Masih dismissed the civil appeal filed by the hospital challenging the concurrent findings of the Andhra Pradesh State Consumer Disputes Redressal Commission (APSCDRC) and the NCDRC. The NCDRC had directed payment of ₹20 lakhs in compensation, ₹15 lakhs to be borne by the hospital and ₹5 lakhs by the attending doctor, Dr. J.V.S. Vidyasagar.
The dispute arose from the death of a young B.Tech graduate who, according to the complainants (his parents), succumbed to avoidable medical complications attributable to negligence during his treatment at Kamineni Hospitals. The hospital contested the finding, arguing that its medical staff had adhered to established standards of care and that there was no expert medical testimony proving negligence.
The Court, however, found no merit in these contentions, observing that the evidentiary record, including medical documents and procedural history, was sufficient to sustain the findings of negligence. It held:
“Having considered the submission made by the Counsel for the parties and upon going through the records of the case, it is apparent that there is ample evidences as well as records to indicate that there was indeed medical negligence at the end of the Appellant and Respondent no.2.”
Rejecting the hospital’s plea that the NCDRC’s compensation was excessive and unsubstantiated, the Court pointed to the young age and educational background of the deceased, noting that the loss of a person with earning potential could not be dismissed lightly, even if his income at the time was modest. It recorded:
“It is evident that he was financially supporting the family and had the qualification and potentiality for earning higher income in future.”
That said, the Court calibrated the quantum of compensation considering the procedural posture of the matter. It recalled that ₹10 lakhs had already been deposited by the hospital pursuant to an earlier interim order and that the accrued interest on this deposit would sufficiently meet the ends of justice. It held:
“We are thus of the considered view that the amount of Rs.10 lakhs as stands deposited in this Court by the Appellant along with the accrued interest thereon would serve the interest of justice and the said amount of compensation would suffice as far as the liability of the appellant hospital is concerned.”
Consequently, while affirming the NCDRC’s decision on liability, the Court modified the compensation payable by the hospital from ₹15 lakhs to ₹10 lakhs with accrued interest. The ₹5 lakhs liability of the doctor remained undisturbed, with the Court noting that the doctor had accepted the NCDRC’s ruling and deposited the amount.
The Court directed that the deposited amount be released to the complainant upon filing of an appropriate application before the Registrar.
The appeals were accordingly disposed of.
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