Supreme Court Quashes NCDRC Ruling, Orders Refund of ₹10 Lakh Compensation in Medical Negligence Case
The Supreme Court on September 9 ordered a complainant to return ₹10 lakh compensation that had earlier been awarded by the National Consumer Disputes Redressal Commission (NCDRC). The Court found that the NCDRC wrongly introduced a new ground of “antenatal negligence” against the doctors, even though the original complaint only concerned “post-delivery negligence.”
A Bench of Justices Sanjay Kumar and SC Sharma ruled that it is not permissible for a forum to create a new case beyond the pleadings. The Court observed that the NCDRC exceeded its jurisdiction by holding the doctor liable for negligence in antenatal care when the complaint never mentioned it.
The case related to the death of the complainant’s wife, who suffered atonic Post-Partum Haemorrhage (PPH) after delivering a stillborn child at Deep Nursing Home. Allegations included delay in arranging blood transfusions, inadequate facilities, mishandling the transfer to PGI Chandigarh, and disclosing the child’s death in an insensitive manner.
The Punjab State Consumer Commission (SCDRC) had earlier held the nursing home negligent and awarded more than ₹20 lakh as compensation. On appeal, the NCDRC found no negligence in delivery or postnatal care, but surprisingly held the doctor liable for not prescribing antenatal tests. This liability, however, had never been part of the original complaint.
The Supreme Court set aside this decision, stating that the NCDRC had clearly “overstepped its power and jurisdiction.” It also noted that since the complainants had not filed an appeal against the finding of no negligence in post-delivery treatment, the matter had already attained finality.
Accordingly, the Supreme Court allowed the appeal and directed the complainant to refund the ₹10 lakh compensation.
Case Title: Deep Nursing Home and another v. Manmeet Singh Mattewal and others
Citation: 2025 LiveLaw (SC) 883
