Supreme Court upholds findings of medical negligence but limits hospital's liability to deposited Rs.10 lakh with interest

A bench of Justices Augustine George Masih and B.R. Gavai heard the appeal by the Managing Director of a private hospital challenging orders of the Andhra Pradesh State Consumer Disputes Redressal Commission (APSCDRC) and the National Consumer Disputes Redressal Commission (NCDRC) that had held the hospital vicariously liable for medical negligence and awarded compensation totalling Rs.20 lakh to the complainant. The appeal contested both liability and the quantum of compensation imposed on the hospital and the treating doctor.

The Court upheld the factual findings of negligence returned by the consumer fora but modified the quantum payable by the hospital. The Court affirmed that there was "ample evidences as well as records to indicate that there was indeed medical negligence at the end of the Appellant and Respondent no.2" and held that the findings of the APSCDRC and NCDRC "cannot be invalidated and are affirmed." The Court accepted that Dr. J.V.S. Vidyasagar had been ordered to pay Rs.5 lakh and had deposited that amount. Noting that this Court had earlier directed the hospital to deposit Rs.10 lakh while issuing notice and that the amount had accrued interest through auto-renewal, the Court concluded 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 therefore reduced the hospital's liability to that deposited amount, to be disbursed to the complainant on application.

Background The dispute arose from the death of the complainant's 27‑year‑old son, a B.Tech graduate employed in a soap factory, following medical treatment at the appellant hospital. The APSCDRC found negligence on the part of the treating doctor and the hospital and the NCDRC, on appeal, imposed joint liability: Rs.15 lakh on the hospital and Rs.5 lakh on the doctor, totalling Rs.20 lakh. The hospital challenged these findings before this Court, contending that the treating professionals had observed the requisite standard of care, supported by medical literature and records, and that no expert evidence established negligence. The complainant supported the consumer fora orders, emphasising the youth and earning potential of the deceased and asserting that the quantum awarded was justified.

The Supreme Court reviewed the pleadings, medical records and the parties' submissions and concluded that the consumer fora had sufficient material to find deficiency in service and medical negligence. The Court noted that the doctor (proforma Respondent No.2) had accepted the order and deposited Rs.5 lakh. While the NCDRC's decision was otherwise upheld, the Court addressed the quantum for the hospital by reference to the interlocutory deposit of Rs.10 lakh previously directed by this Court at the notice stage; that deposit, with accrued interest, was held to be adequate "in the interest of justice" to satisfy the hospital's liability. The appeals were disposed of on these terms and the Registry was directed to disburse the deposited amount to the complainant on an application. No further interim directions were recorded and pending applications stood disposed.

Case No.: 2025 INSC 527; Civil Appeal No(s). of 2025 [@ SLP (CIVIL) No(s). 2948–2949 of 2023] Case Title: The Managing Director, Kamineni Hospitals vs. Peddi Narayana Swami & Anr. Appearances: For the Petitioner(s): Counsel's names not specified in the judgment For the Respondent(s): Counsel's names not specified in the judgment