Case Metadata

• Case: Deep Nursing Home and another v. Manmeet Singh Mattewal and others
• Citation: 2025 INSC 1094
• Court: Supreme Court of India (Civil Appellate Jurisdiction)
• Bench: Sanjay Kumar, J; Satish Chandra Sharma, J
• Decision Date: 09 September 2025
• Appeal No.: Civil Appeal No. 1662 of 2016

Introduction

This judgment arises from a tragic obstetric case in which the patient, Charanpreet Kaur, and her newborn died within hours of delivery at Deep Nursing Home, Chandigarh. The litigation journey traversed the State Consumer Disputes Redressal Commission (SCDRC), the National Consumer Disputes Redressal Commission (NCDRC), and ultimately the Supreme Court of India. The core legal issues before the Supreme Court were:

• Whether the NCDRC could found liability on alleged antenatal negligence when the complaint pleaded only post-delivery negligence and deficient emergency preparedness; and
• How courts and consumer fora should approach allegations of medical negligence, especially where multiple expert Medical Boards opine that the treatment accorded met the standard of care.

The Court reaffirmed fundamental principles of adjudication: fora cannot travel beyond the pleadings to construct a new case, and adverse outcomes alone do not establish medical negligence. It also emphasized institutional deference to specialist medical opinions where consistent, reasoned expert views indicate the absence of negligence.

Summary of the Judgment

• The Supreme Court allowed the appeal, setting aside both the NCDRC’s order dated 09.05.2012 and the SCDRC’s judgment dated 31.01.2007, and dismissed the underlying consumer complaint (Complaint Case No. 56 of 2006).
• It held that the NCDRC erred by imposing liability on Dr. (Mrs.) Kanwarjit Kochhar for antenatal management lapses—a case never pleaded by the complainants, whose allegations were confined to post-delivery negligence and lack of emergency facilities.
• It reaffirmed that consumer fora and courts cannot act as medical experts, and should not substitute their views for specialist opinions, particularly in the face of multiple Medical Board reports consistently finding “no gross medical negligence.”
• The Court noted that the NCDRC expressly found no negligence in delivery and post-delivery management—the very areas pleaded by the complainants. Those exonerating findings, not having been appealed by the complainants, attained finality. The complaint therefore could not survive on a new, unpleaded antenatal theory.
• Refund directions: Respondent No. 1 (the complainant) was directed to refund Rs. 10,00,000 received pursuant to interim orders, in ten monthly instalments of Rs. 1,00,000 each—first three totalling Rs. 3,00,000 to New India Assurance Co. Ltd., and the balance Rs. 7,00,000 to Dr. Kanwarjit Kochhar and Dr. G.S. Kochhar.
• On maintainability, while the Court acknowledged its recent view in Universal Sompo General Insurance Co. Ltd. v. Suresh Chand Jain that SLP under Article 136 against NCDRC’s appellate orders is not the proper remedy, it nevertheless proceeded to decide the matter given the extraordinary delay (over 12 years) and the case already being entertained.

Factual Matrix and Procedural History

Core Facts

• Patient: Charanpreet Kaur (32), in the late stages of pregnancy, under the care of Dr. (Mrs.) Kanwarjit Kochhar at Deep Nursing Home, Chandigarh.
• Event: Delivery occurred at about 2:40 AM on 22.12.2005. The newborn was declared dead at 3:10 AM. The mother suffered atonic postpartum haemorrhage (PPH) and was shifted to PGI, Chandigarh, where she was declared “brought dead.”

Allegations in the Complaint

• Post-delivery negligence: inadequate emergency preparedness, delay in arranging blood transfusion, delay/error in transfer to PGI, lack of a qualified doctor accompanying the patient, and disclosure of the infant’s death causing maternal shock.
• Importantly, there was no allegation of deficient antenatal care or failure to prescribe/respond to necessary investigations before delivery.

Defense and Expert Inquiries

• Defense: The patient suffered unpredictable atonic PPH, was managed as per protocol (investigation for tears, diagnosis of atony, cross-matching and starting transfusions, oxygen/ambu support, calling in senior specialists, and urgent transfer to PGI). Two nurses accompanied; the anaesthetist (Dr. G.S. Kochhar) followed in his car to expedite admission.
• Five expert Medical Board/Committee reports (from Government Hospital, Sector 16 and Government Medical College & Hospital, Sector 32, Chandigarh), all convened at the complainant’s behest, consistently opined that there was no gross medical negligence in management; one report noted uncertainty regarding pre-existing anaemia/hypotension but did not indict the treating team.

SCDRC and NCDRC Findings

• SCDRC (31.01.2007): Found negligence for delay in arranging blood and questioned the transfer protocol, awarding Rs. 20,26,000 (with most to be paid by the insurer). No fault found regarding the infant’s death.
• NCDRC (09.05.2012): Exonerated the nursing home but pinned liability entirely on Dr. Kanwarjit Kochhar. Crucially, it found no negligence in delivery or post-delivery management yet imposed liability on a new ground—alleged antenatal lapses in haematological/cardiological investigations—based on medical literature rather than the pleadings.

Analysis

A. Precedents Cited and Their Influence

• Jacob Mathew v. State Of Punjab (2005) 6 SCC 1: Courts cautioned against presuming negligence merely from an adverse outcome; res ipsa loquitur has limited application in medical negligence. The present judgment echoes this restraint, rejecting inferences drawn solely from the tragic result.
• Martin F. D’Souza v. Mohd. Ishfaq (2009) 3 SCC 1: Courts/consumer fora are not medical experts and should be slow to substitute their judgment for that of specialists; even earnest efforts can fail without constituting negligence. The Court used this to disapprove the SCDRC and NCDRC’s tendency to overreach into medical expertise or selectively rely on general medical literature while discounting concrete, case-specific expert evaluations.
• Devarakonda Surya Sesha Mani v. Care Hospital, IMS (2022 SCC OnLine SC 1608): Absent clear evidence of negligent conduct, courts should not second-guess medical judgment, and every institutional death is not negligence. The Supreme Court relied on this to anchor the threshold for establishing negligence in complex clinical settings like PPH.
• Trojan & Co. v. Rm. N.N. Nagappa Chettiar (1953) 1 SCC 456; Ram Sarup Gupta v. Bishun Narain Inter College (1987) 2 SCC 555; A.V.G.P. Chettiar & Sons v. T. Palanisamy Gounder (2002) 5 SCC 337; Venkataraman Krishnamurthy v. Lodha Crown Buildmart (P) Ltd. (2024) 4 SCC 230; Rama Kt. Barman v. Mohd. Mahim Ali (2024 SCC OnLine SC 4083): These authorities collectively affirm that adjudication is bound by the pleadings; courts cannot decide on grounds or issues never pleaded, as it undermines fair trial and procedural justice. They are the fulcrum of the Supreme Court’s intervention here, invalidating the NCDRC’s shift to antenatal negligence.
• Universal Sompo General Insurance Co. Ltd. v. Suresh Chand Jain (2024) 9 SCC 148: Though generally indicating that SLP under Article 136 is not the proper route against NCDRC appellate orders, the Court declined to relegate the appellants due to a 12-year pendency—an instance of pragmatic exception rather than doctrinal change.

B. The Court’s Legal Reasoning

1. Pleadings bind the proceedings:

   The complainants pleaded post-delivery negligence: inadequate emergency preparedness, delays in blood transfusion and transfer to PGI, and procedural lapses during transfer. There was no allegation that antenatal management was negligent—indeed, the complaint acknowledged that tests had been prescribed and performed pre-delivery.

   The NCDRC’s reasoning pivoted to antenatal lapses (failure to insist on haematological/cardiological investigations) and founded liability solely on the doctor for that distinct period. This was an impermissible recast of the case. The Supreme Court held that the NCDRC overstepped jurisdiction, transgressing settled principles that fora cannot travel beyond the pleadings or surprise parties with unpleaded causes.

2. Expert reports outweigh general literature-driven speculation:

   Five Medical Boards/Committees, convened on the complainant’s own insistence, examined the records and consistently concluded that there was no gross medical negligence in managing the patient and the newborn. One report noted uncertainty regarding pre-existing anaemia/hypotension (owing to insufficient data) but did not find negligence.

   The SCDRC discounted a Board’s opinion as “short” and unreasoned; the NCDRC, while accepting absence of negligence in delivery/post-delivery management, nonetheless imposed liability for a different, unpleaded phase by canvassing medical literature. The Supreme Court corrected course: in medical negligence, general textbooks cannot supplant case-specific expert evaluations, particularly where multiple independent Boards converge on the absence of negligence.

3. Adverse outcomes do not prove negligence; consumer fora are not medical experts:

   Atonic PPH is a known, sometimes catastrophic complication, even with protocol-compliant management. The record showed diagnosis of atony around 03:15 AM, cross-matching, commencement of transfusion at about 04:15 AM, specialist consultations, oxygenation, and expedited transfer with two nurses and running transfusions. In such circumstances—and in the face of convergent expert exonerations—imputing negligence from the tragic outcome violates Jacob Mathew/Martin D’Souza/Devarakonda principles.

4. Finality of findings favourable to the appellants:

   The NCDRC’s clear finding of “no negligence” in delivery and post-delivery care—the only pleaded grounds—was not challenged by the complainants. Those findings attained finality. Since the antenatal negligence theory was unpleaded and impermissible, the complaint could not survive and had to be dismissed.

5. Equitable directions on refund:

   Balancing equities, the Court directed a structured refund of Rs. 10,00,000 withdrawn during the litigation. This ensures restitution without inflicting immediate hardship on the complainant.

C. The Impact of the Judgment

• Reinforcement of pleading discipline in consumer fora: NCDRC and SCDRC must adjudicate within the four corners of the pleadings. Reliance on generic medical literature to invent unpleaded grounds is impermissible. Parties must plead all relevant factual grounds (e.g., antenatal omissions) expressly, or forfeit them.
• Elevated deference to consistent expert medical opinions: Where multiple independent Medical Boards concur that the care met standard protocols, fora should be cautious in attributing negligence absent compelling, case-specific evidence to the contrary.
• Clarity on medical negligence threshold: Adverse outcomes, especially in known high-risk complications like atonic PPH, do not by themselves establish negligence. Concrete proof of a departure from accepted standards and causative linkage is necessary.
• Practical implications for litigants: Complainants must marshal and plead comprehensive allegations, including specific pre-delivery phases if relied upon. Medical practitioners and hospitals should sustain meticulous contemporaneous records (diagnostic times, cross-matching and transfusion start times, specialist calls, transfer logistics), as such records were pivotal here.
• Insurer liability contours: The Court’s dismissal of the complaint and direction to refund sums to the insurer underscores that indemnity hinges on the establishment of negligence; insurers can seek restitution upon ultimate exoneration of the insured/covered risk.
• Procedural note on maintainability: While Universal Sompo counsels against SLPs directly from NCDRC appellate orders, this case illustrates that the Supreme Court may, in exceptional, long-pending matters, decide the controversy rather than relegate parties to Article 226 remedies.

Complex Concepts Simplified

• Consumer Fora: Statutory tribunals under consumer protection laws—State Commissions (SCDRC) and National Commission (NCDRC)—adjudicating consumer disputes, including medical negligence claims treated as “deficiency in service.”
• Pleadings: The formal written statements (complaint/written statement/rejoinders) that define the scope of the dispute. Decisions must be based on issues raised within these pleadings.
• Medical Board/Committee: A panel of specialist doctors constituted by government hospitals/authorities to independently review clinical records and opine on whether the care met accepted standards.
• Postpartum Haemorrhage (PPH): Excessive bleeding following childbirth. “Atonic PPH” occurs when the uterus fails to contract adequately after delivery, leading to heavy bleeding—a leading cause of maternal mortality worldwide, often unpredictable and rapidly catastrophic.
• Cross-matching: Lab testing to ensure compatibility between the patient’s blood and donor blood before transfusion—an essential step that takes time even in urgent scenarios.
• Res ipsa loquitur: A legal maxim (“the thing speaks for itself”) allowing inference of negligence from the mere occurrence of certain accidents. In medical negligence, courts use it sparingly; adverse outcomes alone typically do not invoke it.
• Antenatal vs. Post-delivery care: Antenatal (before birth) care includes routine tests and monitoring during pregnancy. Post-delivery care concerns immediate management after childbirth (e.g., controlling PPH, transfusions, and transfer decisions).
• Ambu bag/oxygen support: Manual resuscitator providing ventilation/oxygen during emergencies.
• Uterine Artery Embolization: A specialized interventional radiology procedure to control severe uterine bleeding. The nursing home’s note that this facility existed only at PGI in North India underscores the necessity of transfer.

Key Observations on the Record

• The first Medical Board explicitly noted: for normal deliveries, blood is not arranged beforehand; here, cross-matching began around 03:15 AM and transfusion commenced around 04:15 AM—undermining the SCDRC’s inference of a two-hour delay.
• The NCDRC acknowledged no negligence in the delivery/post-delivery phases but still imposed liability by invoking unpleaded antenatal shortcomings—precisely what the Supreme Court disapproved.
• No rejoinder was filed by the complainant, and there was no autopsy of the infant—both affecting the evidentiary foundation to prove the pleaded allegations (especially causation).
• The Supreme Court mildly noted the NCDRC’s almost two-year delay between reserving and pronouncing judgment—an administrative concern, though not determinative of the legal issues here.

What the Court Did Not Decide

• It did not articulate a new standard of medical negligence; rather, it reaffirmed existing jurisprudence requiring proof of deviation from standard care and cautioned against substituting judicial views for medical expertise.
• It did not expand on the civil law distinction between “gross” and “ordinary” negligence; though Medical Boards used the phrase “no gross negligence,” the Court treated the composite expert opinions as exculpatory in the civil context of consumer disputes.
• It did not address liability for the newborn’s death, as the SCDRC had found no negligence there and that aspect was not central to the Supreme Court’s ratio.

Practical Takeaways

• For complainants: Plead every phase and theory of negligence expressly (antenatal, intrapartum, postnatal), link alleged departures to outcomes with evidence (records, expert opinions), and file rejoinders where necessary to counter the defense narrative.
• For doctors/hospitals: Maintain detailed, time-stamped records (diagnoses, interventions, calls to specialists, lab timings, transfusion start-times, transfer logistics); these records are often decisive. Engage specialists early in emergencies and document referral rationale.
• For consumer fora: Avoid constructing cases beyond pleadings; give careful, reasoned weight to consistent Medical Board findings; be circumspect in relying on general literature to override case-specific expert conclusions.
• For insurers: Monitor litigation posture and interim payouts; where the insured is exonerated, seek restitution per court directions.

Conclusion

The Supreme Court’s decision in Deep Nursing Home v. Manmeet Singh Mattewal is a robust reaffirmation of two bedrock principles: adjudication must remain tethered to the parties’ pleadings, and medical negligence cannot be inferred from an adverse outcome without proof of a deviation from standard care. By setting aside the NCDRC’s liability finding premised on an unpleaded antenatal theory—and by according due respect to multiple expert Medical Board opinions—the Court has sharpened procedural discipline in consumer medical negligence litigation and fortified deference to specialist assessment in complex clinical scenarios.

The judgment offers clear guidance to consumer fora: do not don the hat of a medical expert; evaluate the case that is pleaded; and where consistent expert panels find standard care, exercise caution before attributing negligence. Equally, it signals to litigants the importance of precise pleadings and meticulous medical records. In the broader legal context, this decision strengthens the integrity of consumer adjudication while ensuring that the medical profession is judged against appropriate legal and clinical standards.