The provided court judgment does not explicitly include the phrase "mere oversight or employment does not automatically impose personal liability." However, the court's reasoning indicates that the employer (the 3rd Defendant) was held vicariously liable for the negligence of the employee (the 1st Defendant), based on the fact that the 1st Defendant was acting within the scope of his employment when performing the RFA procedure (!) (!) .

The court clarified that since the procedure was deemed acceptable and the 1st Defendant was an employee of the employer, the employer’s liability was vicarious, and the employee's conduct did not constitute acting on a "frolic of his own." This suggests that the court did not view employment status alone as imposing personal liability on the employee, especially if the act was within the scope of employment and accepted practice.

Therefore, the concept that "mere oversight or employment does not automatically impose personal liability" aligns with the court's reasoning, which emphasizes that liability depends on whether the employee was acting within the scope of their employment and whether the conduct was acceptable within the responsibilities assigned, rather than simply on employment status alone.