Jyoti Devi vs. Suket Hospital & Ors. (Supreme Court, 23 April 2024)
Background
Jyoti Devi underwent an appendectomy at Suket Hospital, Sundernagar, Himachal Pradesh, on 28 June 2005. The surgery, performed by Dr. Anil Chauhan, was initially considered routine. However, post-surgery, Jyoti Devi experienced persistent pain near the surgical site. She was readmitted on 26 July 2005 but discharged the next day with assurances of recovery. Her pain continued, leading to further treatment and significant suffering over five years.
Alleging medical negligence, Jyoti Devi filed a complaint before the District Consumer Disputes Redressal Commission, seeking compensation for medical expenses and the mental and physical agony she endured. The District Forum found Suket Hospital negligent, awarding her ₹5,00,000 in compensation. On appeal by the hospital, the State Commission reduced the amount to ₹1,00,000. Dissatisfied, Jyoti Devi approached the National Consumer Disputes Redressal Commission (NCDRC), which enhanced the compensation to ₹2,00,000. Still unsatisfied, she appealed to the Supreme Court.
Issues Raised
The primary issues before the Supreme Court were:
Whether the reduction in compensation by the State Commission and NCDRC was justified given the extent of suffering and the established negligence.
The proper application of legal principles such as the Eggshell Skull Rule and the standard for awarding compensation in cases of medical negligence.
Supreme Court’s Analysis
The Supreme Court, comprising Justices Sanjay Karol and Aravind Kumar, reaffirmed the finding of medical negligence by Suket Hospital. The Court observed that the hospital’s post-operative care was deficient, as evidenced by the prolonged pain and suffering of Jyoti Devi and the unrefuted fact of a surgical needle being left in her abdomen. The Court held that the reduction of compensation by the State Commission and NCDRC was unjustified, given the clear evidence of negligence and the significant impact on the appellant’s quality of life.
The Court also addressed the Eggshell Skull Rule, clarifying that it only applies when there is evidence of pre-existing vulnerabilities, which was not the case here. The Court criticized the hospital’s casual approach to post-surgical care and emphasized the need for courts to carefully evaluate evidence before reducing awards in medical negligence cases.
Judgment and Outcome
The Supreme Court allowed Jyoti Devi’s appeal, set aside the orders of the State Commission and NCDRC, and restored the District Forum’s award of ₹5,00,000 as compensation. Additionally, the Court imposed ₹50,000 as litigation costs on the hospital. The judgment underscores the importance of adequate compensation and timely justice for victims of medical negligence.
Significance
This decision strengthens the legal framework for medical negligence claims, emphasizing fair compensation and judicial scrutiny. It also clarifies the application of compensation principles and the Eggshell Skull Rule in medical negligence cases, serving as a precedent for future disputes.
Citation: Jyoti Devi v. Suket Hospital & Ors., [2024] 4 S.C.R. 757; 2024 INSC 330, Supreme Court of India, Judgment dated 23 April 2024.
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