NCDRC Dismisses Medical Negligence Complaint in Young Patient’s Death, Upholds Standard of Care by Treating Hospitals and Doctors

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NCDRC Dismisses Medical Negligence Complaint in Young Patient’s Death,

The National Consumer Disputes Redressal Commission (NCDRC), New Delhi, comprising Justice A.P. Sahi (President) and Mr. Bharatkumar Pandya (Member), has dismissed a consumer complaint alleging medical negligence against Northern Railway Central Hospital, Batra Hospital & Medical Research Centre, and the treating doctors, in connection with the treatment and subsequent death of a young female patient, Ms. Monika Singh, aged approximately 22–23 years.

The Commission held that the complainant failed to establish any deficiency in service, deviation from standard medical practice, or medical negligence, and observed that the allegations were not supported by credible evidence or expert medical opinion. Consequently, the complaint seeking compensation of over ₹1.55 crore was dismissed in its entirety.

Background of the Case

The complaint was filed by Smt. Sarla Devi, mother of the deceased, alleging that her daughter died due to delayed diagnosis, delayed surgical intervention, and negligent postoperative care.

According to the complainant, the patient developed severe abdominal pain and vomiting on 21 July 2015 and was taken to Northern Railway Central Hospital around midnight. It was alleged that the treating doctors provided only symptomatic treatment, tentatively diagnosed appendicitis, refused hospital admission despite repeated requests, and thereby compelled the family to shift the patient to Batra Hospital on 22 July 2015.

The complainant further alleged that upon arrival at Batra Hospital, the patient remained unattended for several hours, that there was an unjustified delay in conducting diagnostic tests including CECT abdomen, delay in surgical intervention, lack of proper ICU access and communication with the family, and misrepresentation of the surgical procedure as a “small operation,” whereas a major intestinal surgery was later discovered to have been performed. Allegations of tampering with medical records were also raised.

It was contended that these alleged lapses cumulatively led to the patient’s deterioration and eventual death on 26 July 2015.

Defence of Northern Railway Central Hospital

Northern Railway Central Hospital denied all allegations of negligence and submitted that the patient was promptly examined in casualty and by the surgical department. The hospital records indicated that the patient’s vital signs were stable, and available ultrasound findings from a prior report suggested renal calculus.

The hospital asserted that appropriate medical management, including injectable medication, was provided, and that the patient and her attendants left the hospital voluntarily after consultation, without waiting for further observation or follow-up. The hospital maintained that there was no unreasonable refusal to admit the patient, and therefore no negligence could be attributed to the institution or its doctors.

Defence of Batra Hospital and Treating Doctors

Batra Hospital and the treating surgeon, Dr. Vijay Hangloo, categorically denied the allegations and contested the factual narrative presented by the complainant. They clarified that the patient arrived at the hospital at approximately 11:00 PM, and not at 4:00 PM as claimed.

The hospital submitted that the patient was immediately evaluated, admitted at 1:15 AM, and started on intravenous antibiotics and supportive treatment. A CECT abdomen was advised and performed, which revealed findings suggestive of ileocecal tuberculosis with perforation and peritonitis.

In view of the grave clinical condition, the patient underwent emergency surgery after obtaining high-risk informed consent from the family. Intraoperatively, extensive fecal contamination and bowel pathology necessitated a right hemicolectomy. Postoperatively, the patient was managed in the ICU with ventilatory support, multidisciplinary critical care, broad-spectrum antibiotics, blood transfusions, and continuous monitoring.

Despite aggressive management, the patient developed septicemia with multiorgan failure and succumbed to her illness. The hospital contended that the outcome was attributable to the severity of the disease and not to any lapse in care.

Findings and Observations of the Commission

After a detailed examination of the pleadings, affidavits, and extensive medical records, the NCDRC found no evidence supporting the allegations of refusal to admit, inordinate delay in treatment, or lack of medical monitoring.

Findings Regarding Northern Railway Central Hospital

The Commission observed that the casualty and OPD records reflected:

Proper clinical examination
Administration of appropriate medication
Sound medical advice based on available findings

There was no evidence to suggest that admission was unreasonably denied or that the patient’s condition was disregarded.

Findings Regarding Batra Hospital

The Commission rejected the claim that the patient arrived at 4:00 PM and remained unattended for several hours. Admission records conclusively established arrival at 11:00 PM with prompt evaluation thereafter. Allegations of tampering with blood pressure readings and treatment charts were also rejected. The Commission noted that minor overwriting or corrections in medical records, by themselves, do not establish fabrication or manipulation, particularly in the absence of corroborative proof.

Medical Evaluation and Legal Reasoning

The Commission emphasized that abdominal tuberculosis with perforation peritonitis is a life-threatening condition with high morbidity and mortality, even with timely intervention. The CECT findings, intraoperative discovery of fecal contamination, extensive bowel involvement, and postoperative deterioration were all found to be consistent with the natural course and severity of the disease.

Importantly, the complainant failed to produce:

Any expert medical opinion
Any authoritative medical literature
Any evidence demonstrating that the adopted line of treatment deviated from accepted medical standards

The Commission observed that it could not be assumed that an earlier CECT or surgery would necessarily have altered the outcome, particularly in such an advanced pathological condition.

Reliance on Supreme Court Precedents

Reiterating well-settled principles of medical negligence law, the Commission relied upon several landmark judgments, including:

Jacob Mathew v. State of Punjab (2005) 6 SCC 1
Kusum Sharma v. Batra Hospital (2010) 3 SCC 480
Bombay Hospital & Medical Research Centre v. Asha Jaiswal (2021 SCC OnLine SC 1149)
Dr. Harish Kumar Khurana v. Joginder Singh (2021) 10 SCC 291
Chanda Rani Akhouri v. M.A. Methusethupati (2022 SCC OnLine SC 481)

The Commission reiterated that an unfavourable outcome or patient death does not, by itself, amount to medical negligence, and that a doctor cannot be faulted for adopting one recognized line of treatment over another.

Final Decision

Concluding that the complainant had failed to establish any deficiency in service or deviation from standard medical practice, the National Consumer Disputes Redressal Commission dismissed the complaint in its entirety. No compensation was awarded against Northern Railway Central Hospital, Batra Hospital & Medical Research Centre, or the treating doctors.