The Supreme Court held that consumer fora cannot travel beyond the pleadings to construct a new case for the complainant. It emphasized that medical negligence cannot be presumed merely because of an adverse treatment outcome. The Court ruled that the NCDRC overstepped its jurisdiction by basing its finding on antenatal care negligence, which was never pleaded by the complainant, and set aside the order.
Facts Of The Case:
A patient, Charanpreet Kaur, died from atonic Post-Partum Haemorrhage (PPH) hours after delivering a stillborn child at Deep Nursing Home, Chandigarh, under the care of Dr. Kanwarjit Kochhar. Her husband, Manmeet Singh Mattewal, filed a consumer complaint alleging medical negligence specifically in the post-delivery treatment. He contended the nursing home was ill-equipped, there was a delay in arranging blood transfusion, and the transfer to a higher care facility was mishandled. The State Commission found negligence and awarded compensation. On appeal, the National Commission exonerated the nursing home and, significantly, held that there was no negligence in the handling of the delivery, the baby, or the post-delivery management. However, it created a new case, holding Dr. Kochhar liable for negligence in antenatal care for not conducting certain haematological tests—a ground never pleaded by the complainant. The Supreme Court overturned this decision, ruling that a consumer forum cannot travel beyond the pleaded case to build a new foundation for liability.
Procedural History:
The legal journey began with a complaint filed by the husband before the State Consumer Disputes Redressal Commission (SCDRC), Chandigarh, which held both the nursing home and the doctor negligent in the post-delivery care and awarded compensation. On appeal, the National Consumer Disputes Redressal Commission (NCDRC) exonerated the nursing home but uniquely pinned liability solely on the doctor, not for the pleaded post-delivery negligence, but for a new, unpleaded ground of negligence in antenatal care. The doctor and nursing home then filed a special leave petition before the Supreme Court, which, despite noting that an appeal under Article 136 was not the ideal remedy against an NCDRC order, entertained the matter due to its long pendency. The Supreme Court ultimately allowed the appeal, setting aside the orders of both the SCDRC and NCDRC and dismissing the original complaint.