Supreme Court Upholds Rigorous Standards for Retinopathy of Prematurity Screening in Medical Negligence Cases: Supreme Court Of India

Introduction

The case of Maharaja Agrasen Hospital And Others v. Master Rishabh Sharma And Others (2019 INSC 1378) adjudicated by the Supreme Court of India on December 16, 2019, marks a pivotal moment in the jurisprudence surrounding medical negligence. The case revolves around allegations of medical negligence by Maharaja Agrasen Hospital and its associated doctors, leading to the permanent blindness of a pre-term infant, Master Rishabh Sharma, due to the failure to conduct mandated Retinopathy of Prematurity (ROP) screenings.

Summary of the Judgment

Respondents, represented by Master Rishabh Sharma's mother, filed a complaint against Maharaja Agrasen Hospital and several of its doctors for medical negligence. The National Consumer Disputes Redressal Commission (NCDRC) initially found the hospital and the pediatricians guilty of negligence for failing to perform ROP screenings, which resulted in the child's total blindness. The hospital and doctors appealed the decision, seeking to diminish the compensation awarded. However, the Supreme Court upheld the NCDRC's findings, affirming the negligence and deficiency in service. The Court directed the appellants to pay an enhanced compensation to the complainants, emphasizing the importance of adhering to medical protocols to prevent such tragedies.

Analysis

Precedents Cited

The judgment extensively references several landmark cases that have shaped the standards of medical negligence in India:

Bolam v. Friern Hospital Management Committee (1957): Established the Bolam test, which assesses medical negligence based on whether the practitioner's actions align with a responsible body of medical opinion.
Jacob Mathew v. State of Punjab (2005): Reinforced the application of the Bolam test in Indian courts, emphasizing the need for medical professionals to exhibit reasonable competence.
V. Krishnakumar v. State of T.N. (2015): Highlighted the necessity of adhering to standard medical protocols, particularly concerning ROP screening, and emphasized the preventability of blindness through timely intervention.
Bolitho v. City & Hackney Health Authority (1998): Modified the Bolam test by introducing a requirement that the medical opinion relied upon must withstand logical analysis.
Montgomery v. Lanarkshire Health Board (2015): Shifted the focus towards patient autonomy and informed consent, moving away from the Bolam test in certain contexts.

These precedents collectively influenced the Court's approach, balancing established standards with the evolving expectations of patient care and autonomy.

Legal Reasoning

The Supreme Court's legal reasoning centered on the breach of duty of care by both the hospital and the attending doctors. Key points include:

Duty of Care: The hospital and doctors had a legal obligation to provide competent medical care, including adhering to standard protocols for ROP screening in pre-term infants.
Breach of Duty: The failure to conduct the mandatory ROP checkups, despite the baby being pre-term and at high risk for ROP, constituted a breach of this duty.
Causation: This breach directly resulted in the child’s total blindness, which was deemed a foreseeable consequence of negligent medical care.
Vicarious Liability: The hospital was held vicariously liable for the actions of its employed doctors, emphasizing institutional responsibility in ensuring compliance with medical standards.
Assessment of Compensation: The Court reviewed the compensation awarded by the NCDRC, considering factors like inflation, long-term care costs, and the impact on the child’s education and quality of life, ultimately enhancing the compensation to meet the ends of justice.

Impact

This judgment has significant implications for the medical community and legal practitioners:

Reinforcement of Medical Protocols: Hospitals and medical professionals are compelled to strictly adhere to established medical protocols, especially for high-risk conditions like ROP.
Legal Accountability: Enhances the accountability of medical institutions and practitioners, ensuring that systemic failures leading to patient harm are addressed.
Guidance for Future Cases: Serves as a precedent for evaluating negligence in similar medical cases, providing a clear framework for duty, breach, and causation.
Patient Rights: Aligns with the evolving jurisprudence that emphasizes patient rights and informed consent, necessitating transparent communication between healthcare providers and patients.

Complex Concepts Simplified

Retinopathy of Prematurity (ROP): A potentially blinding eye disorder that primarily affects premature infants with low birth weight. It involves abnormal development of retinal blood vessels, which can lead to retinal detachment and blindness if not detected and treated promptly.
Bolam Test: A legal principle used to determine medical negligence. It states that a medical professional is not negligent if their actions align with a practice accepted by a responsible body of medical professionals.
Vicarious Liability: A legal doctrine where an institution (like a hospital) is held responsible for the actions or omissions of its employees (like doctors) performed in the course of their employment.
Duty of Care: A legal obligation requiring medical professionals to adhere to a standard of reasonable care while performing any acts that could foreseeably harm patients.
Duty of Care in Medical Negligence: Specifically relates to the obligation of healthcare providers to prevent harm to patients by following established medical standards and protocols.

Conclusion

The Supreme Court's judgment in Maharaja Agrasen Hospital And Others v. Master Rishabh Sharma And Others serves as a critical reminder of the paramount importance of adhering to medical protocols to prevent patient harm. By upholding the principles of duty of care and reinforcing the standards established by precedents like the Bolam test, the Court has emphasized the need for medical professionals and institutions to maintain high standards of practice. This decision not only ensures accountability but also safeguards the rights of patients, promoting a medical environment where negligence is systematically addressed and prevented.

Moving forward, this judgment is expected to influence both medical practice and legal adjudication in India, fostering a culture of diligence, transparency, and responsibility within the healthcare sector. It underscores the judiciary's role in upholding patient welfare and ensuring that medical negligence cases are adjudicated with due consideration to both legal standards and ethical imperatives.

Supreme Court Upholds Rigorous Standards for Retinopathy of Prematurity Screening in Medical Negligence Cases