Supreme Court Awards Rs. 6.08 Crores Compensation in Landmark Medical Negligence Case Involving Death of US Citizen in India

Apex Court Enhances Compensation, Rejects Multiplier Method for Medical Negligence Claims, and Holds Hospital Vicariously Liable

In a landmark judgment dated October 24, 2013, the Supreme Court of India delivered a comprehensive verdict in the medical negligence case concerning the death of Anuradha Saha, a US citizen and child psychologist, during treatment in Indian hospitals. The case, arising from the tragic demise of the claimant Dr. Kunal Saha’s wife due to alleged medical negligence, underscores critical principles concerning compensation for medical negligence in India.

The Supreme Court, while hearing multiple appeals filed by the doctors involved, the AMRI Hospital, and the claimant himself, significantly enhanced the quantum of compensation awarded to the claimant from Rs. 1.34 crores to Rs. 6.08 crores, inclusive of interest at 6% per annum from the date of filing the complaint. The apex court emphatically rejected the application of the multiplier method—as prescribed under Section 163A of the Motor Vehicles Act, 1988—for computing compensation in medical negligence cases, emphasizing the need for a just, fair, and reasonable assessment based on the actual income and status of the deceased.

The court held that the deceased's income should be assessed in light of her status as a child psychologist in the US, her qualifications from a prestigious Ivy League School, and the standard of living in the United States. Accepting expert testimony from Prof. John F. Burke, an economist, the court recognized a fair income estimate of $40,000 per annum, adjusted for future prospects and personal expenses, and converted at an exchange rate of Rs. 55 per dollar. Consequently, the compensation for loss of income alone was fixed at Rs. 5.72 crores.

Additional heads of compensation included medical treatment expenses in Kolkata and Mumbai (Rs. 7 lakhs), travel and hotel expenses during treatment (Rs. 1.5 lakhs), loss of consortium (Rs. 1 lakh), pain and suffering endured by the deceased during treatment (Rs. 10 lakhs), and litigation costs (Rs. 11.5 lakhs). The court dismissed claims of emotional distress compensation for the claimant himself as lacking direct nexus to the negligence.

The judgment reaffirmed the fundamental right to health under Article 21 of the Constitution, cautioning doctors, hospitals, and nursing homes to exercise utmost care and diligence. It directed stringent scrutiny of private and government medical establishments to prevent negligence.

On liability, the court held the AMRI Hospital vicariously liable for the negligence of its doctors and ordered the hospital to pay the bulk of compensation after deducting amounts already paid by the doctors. The three doctors involved were ordered to pay Rs. 10 lakhs each (two senior doctors) and Rs. 5 lakhs (junior doctor) respectively, reflecting their respective degrees of negligence. The court criticized the doctors for attempting to shift blame and underscored the ethical duty of medical professionals.

Importantly, the court rejected the finding of contributory negligence against Dr. Kunal Saha, the claimant, absolving him of any deduction in compensation. It also recognized the long pendency of the case (over 15 years) and the resulting devaluation of money due to inflation, which justified enhancement of compensation.

This judgment sets a precedent by highlighting that compensation for medical negligence must consider the victim’s actual status, future prospects, and international standards where applicable, rather than applying mechanical formulas designed for motor accident claims. It also sends a strong message to the medical fraternity about accountability and the dire consequences of negligence.

Statutory provisions

Consumer Protection Act, 1986 Sections 12, 13; Motor Vehicles Act, 1988 Sections 158(6), 163A; Indian Penal Code Section 304A; Constitution of India Articles 21, 136

Dr. Balram Prasad v. Dr. Kunal Saha (SC) : Law Finder Doc Id # 490019