Supreme Court Clarifies 'Eggshell Skull Rule' in Medical Negligence Case

In Jyoti Devi v. Suket Hospital & Ors., Supreme Court clarifies 'Eggshell Skull Rule' in medical negligence, ensuring fair compensation for victims.

In a significant legal development, the Supreme Court provided clarity on the application of the ‘Eggshell Skull Rule’ in a medical negligence case. This rule, rooted in common law, holds a defendant responsible for unforeseeable and uncommon reactions of the plaintiff to negligent or intentional actions.

The Court emphasized that this rule applies specifically when the victim possesses a pre-existing vulnerability or medical condition. A two-Judge Bench comprising Justice Sanjay Karol and Justice Aravind Kumar delved into the intricacies of this doctrine while addressing an appeal filed by a woman against a hospital, seeking increased compensation.

The Bench quoted, “This rule (applied by the NCDRC) holds the injurer liable for damages that exceed the amount that would normally be expected to occur. It is a common law doctrine that makes a defendant liable for the plaintiff's unforeseeable and uncommon reactions to the defendant's negligent or intentional tort.”

The case revolved around the ordeal faced by the claimant after undergoing appendicitis surgery at Suket Hospital, Sundernagar, Mandi, Himachal Pradesh. Despite the procedure, she continued to suffer from persistent pain near the surgical site. Subsequent investigations revealed the presence of a foreign body (needle) necessitating further surgery.

The claimant alleged negligence on the hospital's part and sought compensation for the physical and financial toll she endured. The lower consumer dispute redressal bodies partially upheld her claim, leading to an appeal before the Supreme Court.

The Court acknowledged the significance of the Eggshell Skull Rule in determining liability beyond what may be anticipated in typical circumstances. It categorized scenarios where this rule applies, emphasizing the necessity of a pre-existing condition falling into specific categories for its invocation.

Furthermore, the Court elucidated the essence of the Consumer Protection Act, emphasizing its aim to safeguard consumer interests by providing accessible and prompt remedies for grievances arising from defective goods or deficient services.

In assessing compensation for medical negligence, the Court stressed the principles of adequacy, fairness, and equity. It highlighted the objective of restitution, aiming to restore the claimant to a position as if the loss or injury hadn’t occurred. The Court deemed the compensation awarded to the claimant insufficient, considering her suffering and absence of fault.

Addressing the application of the Eggshell Skull Rule in the case, the Court noted a lack of clarity in the lower judgments regarding the claimant's pre-existing condition and its susceptibility to adverse reactions from the surgery.

Consequently, the Supreme Court allowed the appeal, overturning the decisions of the lower bodies and reinstating the compensation awarded by the District Forum. The respondents were directed to pay Rs. 5 lakhs to the appellant.