Supreme Court Upholds Hospital's Vicarious Liability For Doctor's Negligence

The Supreme Court today (April 22) upheld the NCDRC's finding of the hospital being vicariously liable for the medical negligence of the doctor, which caused the death of a patient.

The NCDRC imposed a total compensation of ₹20 lakhs (₹15 lakhs on the hospital and ₹5 lakhs on the doctor), leading to an appeal before the Supreme Court by the Hospital.

Affirming the NCDRC's findings, the bench comprising Justices BR Gavai and AG Masih held in favor of the claimants, whose son was operated in the Appellant's hospital by a Doctor, resulting in his death due to medical negligence.

The Court noted that there was sufficient evidence (medical records, treatment history) to conclude negligence, and the hospital failed to disprove negligence despite claiming adherence to standard care.

“Having considered the submission made by the Counsel for the parties and upon going through the records of the case, it is apparent that there is ample evidences as well as records to indicate that there was indeed medical negligence at the end of the Appellant and Respondent no.2.”, the court said.

Since the hospital had already deposited ₹10 lakhs (as per an earlier Court's interim order), the accrued interest on this deposit was deemed sufficient compensation. Moreover, considering the fact that the deceased was young (27) and a B.Tech graduate, his actual earnings were modest, and future income was speculative, the Court deemed it appropriate to grant Rs. 10 lacs as compensation as already deposited by the Appellant.

“As regards the amount of Rs. 15 lakhs is concerned which is assessed to be paid as compensation by the Appellant, it would not be out of way to mention here that while issuing notice in the present case, this Court had directed the Appellant to deposit an amount of Rs.10 lakhs in the Registry of this Court to be invested in short term fixed deposit to be renewed from time to time. We have been informed that the said amount has increased with the auto renewal facility over a period of time. We are thus of the considered view that the amount of Rs.10 lakhs as stands deposited in this Court by the Appellant along with the accrued interest thereon would serve the interest of justice and the said amount of compensation would suffice as far as the liability of the appellant hospital is concerned.”, the court observed.

In terms of the aforesaid, the Court disposed of the case.

Case Title: THE MANAGING DIRECTOR, KAMINENI HOSPITALS Vs. PEDDI NARAYANA SWAMI & ANR.

Citation : 2025 LiveLaw (SC) 453

Click here to read/download the judgment

Appearance:

For Petitioner(s) : Ms. Aruna Gupta, AOR Mr. Ramesh Allanki, Adv. Mr. Syed Ahmad Naqvi, Adv.

For Respondent(s) : Mrs. K.Radha, Adv. Mr. K.maruthi Rao, Adv. Mrs. Anjani Aiyagari, AOR Ms. Ekta Choudhary, AOR Mr. Ayush Kumar, Adv. Mr. Anand Krishna, Adv.