Upholding Patient Rights: Supreme Court's Verdict on Medical Negligence in Najrul Seikh vs. Dr. Sumit Banerjee & Anr

The Supreme Court emphasized the primacy of Consumer Forum findings over Medical Council reports in cases of medical negligence, underscoring patient rights. In Najrul Seikh vs. Dr. Sumit Banerjee & Anr, it upheld compensation for a boy's vision loss post-cataract surgery.

In a recent judgment, the Supreme Court of India delivered a significant ruling regarding medical negligence, emphasizing the primacy of consumer forums' factual findings over reports by medical councils. The case, Najrul Seikh vs. Dr. Sumit Banerjee & Anr, revolves around a BPL cardholder whose son suffered complete vision loss in one eye following cataract surgery. Despite a report by the Medical Council, the Court upheld the District Consumer Disputes Redressal Commission's (DCDRC) decision to award compensation to the complainant.

The legal dispute stemmed from the conflicting findings between the consumer forums and the Medical Council regarding medical negligence. The District Consumer Disputes Redressal Commission (DCDRC) initially ruled in favor of the complainant, holding the doctor liable for negligence. However, the State Commission (SCDRC) overturned this decision, relying on a report by the Medical Council that purportedly exonerated the doctor. Subsequently, the National Consumer Disputes Redressal Commission (NCDRC) affirmed the SCDRC's order, prompting the complainant to appeal to the Supreme Court.

The crux of the matter before the Supreme Court was the relevance and weight to be accorded to the Medical Council's report vis-à-vis the factual findings of the consumer forums. The Court underscored that while the report could be pertinent in assessing service deficiency, it should not be determinative, especially when it contradicts the evidence presented before the consumer forum. The Court criticized the SCDRC and NCDRC for mechanically relying on the Medical Council's report without adequately considering the expert testimony and evidence presented by the complainant.

Moreover, the Supreme Court highlighted the duty of appellate forums to conduct a thorough examination of the evidence, particularly when parties raise substantive arguments challenging the lower forum's findings. In this case, the Court noted the failure of the SCDRC and NCDRC to address the complainant's arguments effectively, leading to an erroneous reliance on the Medical Council's report.

The Court's analysis reaffirmed the principle that in cases of medical negligence, the duty of care extends beyond surgery, emphasizing the importance of post-operative management and rehabilitation. It cited the admission by the respondents regarding the complexities and risks associated with traumatic cataract management in children, further bolstering the consumer forum's findings of service deficiency.

Ultimately, the Supreme Court upheld the DCDRC's decision to award compensation to the complainant, emphasizing the robustness of its factual findings and the inadequacy of the Medical Council's report to rebut them. The Court's ruling serves as a precedent for prioritizing consumer forums' assessments of medical negligence over external expert opinions, underscoring the judiciary's commitment to protecting consumers' rights and ensuring accountability in healthcare.

In conclusion, the Najrul Seikh case highlights the intricate balance between medical expertise and legal adjudication in cases of alleged medical negligence. By affirming the primacy of consumer forums' findings and critiquing the indiscriminate reliance on external reports, the Supreme Court reaffirmed the pivotal role of judicial scrutiny in safeguarding patients' interests and upholding the standards of medical practice.