Summary and Analysis of Deep Nursing Home & Anr vs Manmeet Singh Mattewal & Ors 2025 INSC 1094

1. Heading of the Judgment

Case Name: Deep Nursing Home and another vs Manmeet Singh Mattewal and others
Citation: 2025 INSC 1094 (Civil Appeal No. 1662 of 2016)
Court: Supreme Court of India
Judges: Hon'ble Mr. Justice Sanjay Kumar and Hon'ble Mr. Justice Satish Chandra Sharma
Nature of Case: Civil Appeal against a decision of the National Consumer Disputes Redressal Commission (NCDRC) in a medical negligence case.

2. Related Laws and Sections

This case revolves around the law of medical negligence within the framework of consumer protection. The key legal principles invoked are:

• Consumer Protection Act, 1986: The case was filed as a complaint alleging "deficiency in service" by a medical professional.

• Principles of Medical Negligence: The judgment applies the well-established legal tests for proving medical negligence, as laid down in previous Supreme Court rulings:
  Jacob Mathew vs. State of Punjab (2005): Held that a doctor cannot be held liable merely because a treatment failed. The doctrine of res ipsa loquitur (the thing speaks for itself) does not apply automatically in medical cases.
  Martin F. D’Souza vs. Mohd. Ishfaq (2009): Reiterated that courts and consumer fora are not medical experts and must not substitute their own views over that of specialists.
  Devarakonda Surya Sesha Mani vs. Care Hospital (2022): Emphasized that a specific course of conduct suggesting a lack of due care must be established; every death in a hospital is not negligence.

• Principles of Pleadings: The judgment crucially relies on the fundamental rule of civil law that a case must be decided based on the grounds pleaded by the parties. It cites precedents like Trojan & Co. vs. Nagappa Chettiar (1953) and Ram Sarup Gupta vs. Bishun Narain Inter College (1987) to state that a court cannot build a new case for a party that they never made themselves.

3. Basic Judgment Details

• Appellants (Medical Professionals):
  Deep Nursing Home, Chandigarh
  Dr. (Mrs.) Kanwarjit Kochhar (Obstetrician/Gynaecologist)

• Respondents (Complainants):
  Manmeet Singh Mattewal (Husband of the deceased)
  Shiraz Mattewal (Son of the deceased)
  New India Assurance Company Ltd. (Insurer)

• Subject of Dispute: Alleged medical negligence leading to the death of Charanpreet Kaur (patient) shortly after childbirth.

• Lower Fora Decisions:
  State Commission (SCDRC), Chandigarh (2007): Held both the doctor and the nursing home negligent in post-delivery care. Awarded compensation of approx. ₹20.26 lakhs.
  National Commission (NCDRC) (2012): Acquitted the nursing home but held Dr. Kochhar negligent, not in post-delivery care (as alleged) but in antenatal care—a point never raised by the complainant. Upheld the compensation amount, making the doctor solely liable.

• Supreme Court's Decision: Allowed the appeal. Set aside the orders of both the State and National Commissions and dismissed the original complaint. Directed the complainant to refund the compensation amount received.

4. Explanation of the Judgment

Core Legal Issue

The central question was whether the National Commission (NCDRC) acted within its jurisdiction by holding the doctor guilty of negligence on a ground (deficiency in antenatal care) that was never pleaded, argued, or proved by the complainant, thereby creating a completely new case for him.

Background Facts

Charanpreet Kaur, under the care of Dr. Kochhar, delivered a baby at Deep Nursing Home. The newborn died shortly after birth. The mother then suffered a catastrophic Post-Partum Haemorrhage (PPH—a known complication where the uterus fails to contract after delivery, causing massive bleeding). Despite efforts at the nursing home and during transit to a specialized hospital (PGI, Chandigarh), she also passed away.

The husband, Mr. Mattewal, filed a consumer complaint alleging specific negligence only in post-delivery care:

• The nursing home was ill-equipped to handle emergencies.

• There was a delay in arranging blood transfusion.

• The doctor's husband did not accompany the patient in the ambulance.

• The patient was informed of the baby's death, causing shock.

He never alleged any negligence during the antenatal (pre-birth) check-ups.

The Supreme Court's Analysis and Reasoning

The Supreme Court allowed the doctor's appeal and dismissed the complaint based on two profound legal errors committed by the National Commission.

1. Unanimous Medical Expert Opinions Were Ignored:
Mr. Mattewal himself had triggered multiple investigations. Five separate Medical Boards, comprising senior government doctors and professors, investigated the case. All five concluded unanimously that there was "no gross medical negligence" in the management of the patient by Dr. Kochhar.

• The Court emphasized that consumer fora are not medical experts. When multiple specialized boards have cleared the doctor of negligence, the NCDRC was wrong to disregard their unanimous opinion based on its own interpretation of medical literature.

2. The NCDRC Built a New Case Beyond the Pleadings (Fatal Error):
This was the most critical legal flaw identified by the Supreme Court.

• The complainant's case was specifically and solely about negligence in post-delivery emergency care.

• However, the NCDRC, in its order, explicitly held that there was NO negligence in the delivery, the management of the baby, or the post-delivery care. This alone should have led to the complaint's dismissal.

• Instead, the NCDRC invented a new case. It held Dr. Kochhar negligent for failing to conduct certain haematological (blood-related) tests during the antenatal period.

• The Supreme Court strongly condemned this. It is a settled principle of law that a court cannot travel beyond the pleadings of the parties. A judge cannot make a case for a party that they never made themselves. The NCDRC's entire basis for finding negligence was on a ground that was never alleged, pleaded, or proved. This was a gross overstepping of its jurisdiction.

The Court reasoned that once the NCDRC itself found no negligence in the specific allegations made by the complainant, it had no legal basis to uphold the complaint on a completely different, self-invented ground.

Supreme Court's Directions and Conclusion

The Supreme Court held that the NCDRC's judgment was unsustainable in law as it was based on an entirely new case not pleaded by the complainant.

Final Decision: The Supreme Court:

• Allowed the appeal filed by the doctor and the nursing home.

• Set aside the orders of the NCDRC and the SCDRC.

• Dismissed the original consumer complaint (Case No. 56 of 2006).

• Directed the complainant, Manmeet Singh Mattewal, to refund the total sum of ₹10,00,000 (which he had received during the litigation) to the doctor and the insurance company in monthly installments.