No Cure Is Not Negligence; Doctor Not Liable if Standard Medical Protocol Followed For Critically Ill Patient: Punjab SCDRC - 2025-09-12

Punjab State Commission Overturns Medical Negligence Ruling, Exonerates Doctor and Hospital

Chandigarh, Punjab - The State Consumer Disputes Redressal Commission (SCDRC), Punjab, has set aside a District Commission order, ruling that a doctor and hospital cannot be held liable for medical negligence when the treatment provided adheres to standard medical protocols, especially when the patient was admitted in a critical condition with multiple pre-existing fatal diseases.

The bench, comprising Mr. H.P.S. Mahal, Presiding Judicial Member, and Mrs. Kiran Sibal, Member, allowed the appeals filed by Dr. Amandeep Singh and the Punjab Institute of Medical Sciences (PIMS), Jalandhar, exonerating them from the charge of negligence in the death of Surinder Kaur in 2017. The Commission overturned the District Commission's award of ₹8 lakh in damages to the patient's husband, Gurdial Singh.

Background of the Case

Gurdial Singh had filed a complaint alleging that his wife, Surinder Kaur, died due to medical negligence at PIMS. She was admitted on February 8, 2017, in a serious condition and passed away on February 10, 2017. The complainant contended that the hospital and Dr. Amandeep Singh were negligent on two main grounds: failing to insert a "central line" for administering medication despite having purchased the necessary kit, and administering a wrong line of treatment for Type-II Diabetes, a condition he claimed his wife never had.

The District Commission, Jalandhar, had partly accepted the complaint, finding the hospital, the doctor, and the PIMS Medical and Education Charitable Society jointly and severally liable, and directed them to pay ₹8,00,000 as damages and ₹10,000 as litigation expenses.

Arguments from Both Sides

Complainant's Arguments (Gurdial Singh): - The hospital assured him that a central line fixation was necessary and was the sole reason for shifting his wife to the ICU. Despite purchasing the required materials, the procedure was never performed. - His wife was wrongly treated for Type-II Diabetes Mellitus, when she actually suffered from Hypothyroidism and Hypertension. He provided lab reports showing normal or nil sugar levels prior to admission. - The administration of Dopamine to a patient with a history of hypertension was further proof of a wrong line of treatment.

Appellants' Arguments (Dr. Amandeep Singh & PIMS): - The patient was admitted in a very critical state with multiple life-threatening conditions, including pneumonia, sepsis, acute liver and kidney injury, and portal vein thrombosis, not merely for a central line insertion. - A central line was not needed as the patient's veins were traceable, and medicines were successfully administered intravenously. Furthermore, the patient's Prothrombin Time (PT/INR) was 4.7%, indicating a high risk of bleeding, which made the insertion of a central line medically inadvisable (a contraindication). - The diagnosis of Type-II Diabetes was based on the history provided by the patient's relatives and confirmed by blood sugar readings at the hospital, which were as high as 163 mg/dl upon admission and 253 mg/dl shortly before her death. The patient was monitored closely, and dextrose was administered when her sugar levels dropped. - The patient's death was an unfortunate outcome of her grave, multi-organ illnesses and not due to any deficiency in care.

Commission's Analysis and Ruling

The State Commission conducted a detailed review of the medical records and evidence submitted by both parties. It systematically dismantled the grounds on which the District Commission had found negligence.

On the Issue of Central Line Fixation: The Commission observed that medical records, including the 'Intake-Output Chart' and 'Drug Administration Record', clearly showed that the patient was receiving fluids and medicines intravenously throughout her 35-hour stay. It found merit in the doctor's argument that the high PT(INR) level of 4.7% posed a significant bleeding risk, making the procedure unsafe. The Commission concluded:

"Accordingly, we find no force in the contention of respondent No.1/complainant that OPs are negligent in not inserting the center line in the body of his wife... The District Commission has wrongly held the OPs negligent for not inserting the central line..."

On the Wrong Line of Treatment: The Commission noted that the hospital's 'Blood Sugar/Insulin Chart' documented fluctuating blood sugar levels, which supported the diagnosis of Type-II Diabetes. It reasoned that the initial diagnosis was based on the patient's history provided by relatives, a standard medical practice. The records confirmed that the patient was suffering from multiple fatal diseases.

"Hence, there is force in the contention of appellant/OP No.2 that the patient was diabetic and the treatment given to the patient was ethical as per the standard medical protocol and according to her disease pattern."

Citing the Supreme Court's landmark judgment in Kusum Sharma & others Vs. Batra Hospital & Medical Research Centre & others , the Commission reiterated established legal principles that a doctor is not negligent if their conduct meets the standards of a reasonably competent practitioner and that a medical professional would be liable only when their conduct falls below that standard.

Final Decision

The State Commission concluded that the patient was a high-risk case with multiple critical illnesses and the treatment provided was in accordance with standard medical norms. Finding no evidence of negligence or deficiency in service, the Commission allowed both appeals and set aside the impugned order of the District Commission. The amounts deposited by the appellants are to be refunded to them.