This article was written by: Udayanta Das, Sanjucta Das, and Soumyadeep Das from AUK
STATEMENT OF PURPOSE
In current medical practice, the essential fundamental remaining parts “cause no damage.” Yet, occurrences of clinical carelessness are accidental oversights or purposeful acts of neglect that outcome in mischief to patients appear to challenge the sacredness of this standard. As medical care frameworks all over the planet endeavor to offer the most ideal patient consideration, understanding the underlying drivers, commonness, and repercussions of clinical carelessness becomes pivotal. This examination expects to dive profound into the peculiarity of clinical carelessness in [specific nation or well-being institution]. It looks to reveal insight into the elements prompting clinical carelessness, the effect it has on patients and their families, the legitimate scene encompassing it, and possible preventive methodologies. Through this review, we intend to add to more secure medical services rehearses, more educated arrangement-making, and expanded public mindfulness, guaranteeing that each understanding gets care that isn’t just compelling but additionally protected.
Mistake in medication and clinical risk has a long history tracing all the way back to the relic. During the 19th century, most claims connected with mistakes in treating careful issues were settled. In any case, in the main portion of the 12th century, claims guaranteed that missteps were connected with the specialist’s activity: the specialist made something wrong (blunders of commission). In Brazil, clinical blunder is characterized as unseemly lead, including carelessness and foolishness, that hurt the patient. The doctor’s anxiety toward being fit is an ideal justification for some training named cautious Medication (D.M.), characterized as requesting superfluous tests and methods or staying away from medicines for patients considered at high risk. Subsequently, this account survey means to break down and depict the connection between clinical blunders, clinical carelessness, and the act of D.M. In this way, the creators propose strategies and mentalities to stay away from clinical mistakes and the methodology of D.M.: a public concentration to take initiative and examination apparatuses to upgrade the information base about persistent security; a detailing framework that would assist with distinguishing and gain from blunders; the utilization of a PC based convention update; mechanical gadgets to help the clinical practice (electronic endorsing and data innovation frameworks); making risk the executives programs in medical clinics. Subsequently, the creators reason that the most basic mentality to keep away from clinical responsibility is a decent and moral clinical practice with the legitimate utilization of innovation, in light of information on logical proof and moral standards of medication – to help patients.
The term ‘negligence’ means ‘want of care’. So, negligence is the failure to do something which is expected to be done by a prudent person.
The phrase ‘Medical negligence’ is used to denote the failure to meet the standard of care The exact time when the concept of medical negligence came into existence is not known to anybody. However, as per the studies, the concept dates back to the Code of Hammurabi, 1954 BC. At the time of Hammurabi, a medical practitioner whose reluctance caused the death of a person, would be liable for his reluctance.
Medical negligence also had its traces in Roman Law. The Romans believed in the liability of the medical practitioners in case of their malpractice, which could have reasonably been prevented. After the code of Hammurabi, the concept, and practice of medical negligence started to be assimilated in every society as the main motto of this concept was for the doctors to be held liable.
In the year 1374, Stratton versus Swanlond cropped up as the first case of medical negligence although it was dismissed on procedural grounds.
In India, the journey of medical negligence experienced several ups and downs. The concept of medical negligence was initially dealt with by the provisions of the Indian Penal Code and eventually made its place in civil law. As per the provisions of the Consumer Protection Act, the sufferers of medical negligence can claim compensation.
In 2005, the guidelines related to the medical negligence has been prescribed in case of Jacob Mathew versus State of Punjab & Anr. (2005) 6 SCC 1. As per this guideline, the claimants were entitled for compensation from the medical practitioner. This case dealt with the issue when an act of a medical practitioner would come under the purview of medical negligence and how to deal with the same. This case also applied a test namely BOLAM Test to identify the act of medical negligence.
Every act consists of a ‘standard of care’ and the person doing such an act should fulfil his duty to take care.
The Medical profession is one of the noblest profession in the world and time and again it has to go under the scrutiny of the ‘standard of care’ as well as the ‘duty of care’.
A medical practitioner or a person who represents him as an efficient person to provide medical advice, has some duty towards the persons who consults with him and failure to which gives birth to a case of medical negligence
The medical negligence is the result of subordinate standard of care, the breach of duty to take care, use of low quality equipments, lack of knowledge etc.
In India generally the cases relating to medical negligence comes before the civil court but the death caused due to medical negligence is dealt with the penal provisions of law.
Types and elements of medical negligence
Types of medical negligence
1. Missed Diagnosis or Misdiagnosis: When there is an intentional delay in the diagnosis of a patient or the medical practitioner fails in the identification of the problem of the patient; thus resulting in the in unsuitable treatment and worsening condition of the patient.
2. Surgical mistakes: According to a survey, Despite the awareness of the condition of the patient; 10% of the patient’s harm was due to certain mistakes in pre-surgery and post-surgery. The certain types of mistakes includes inappropriate incisions, foreign materials in the human body, organ failure due to misconduct, wrong-site surgery etc.
3. Prescription errors: These are the types of errors that occur due to the wrong prescribed medications to the patient by the medical practitioners which results in potential drug allergies, overdose or worse death.
4. Birth injuries:- The injuries that occur during the birth of a child comes under this category. Often times the tools used in child birth are not sterile which causes discomfort to the mother and leads to infections. The injuries can also happen due to using the delivery equipments in a certain way during a caesarean section or a normal delivery which can cause swelling of the soft tissue of the baby’s scalp. This usually happens when the baby travels through the birth canal from a vacuum assisted delivery.
5. Dose mistakes:- These are the types of mistakes that usually happens in the dosage of anesthesia while applying it to the patient. The doctors usually fail to check or keep a track on the patient’s vitals and results in overdosing the patient.
6. Inability to gain Full Assent: This usually happens when the medical practitioner or the non-medical staff fails to know the proper history of the patient before the diagnosis or executing a medical operation. The insufficient data results in the disadvantage of the patient’s health.
7. Inability to Give Sufficient Follow-Up Care: Sometimes even the medical professionals fail to properly care or administer the patient post-surgery that leads to infections or other adverse events.
8. Negligence in nursing homes or long-term care facilities:- The failure to provide older or seriously ill patients the appropriate healthcare by the staff that leads to either serious health conditions or death of the patients.
9. Issues when communicating:- Healthcare professionals sometimes due to miscommunications or disruptions in test findings results in negligence or transitions of care.
10. Defects that are devices- or facilities-related:– This becomes an issue when the professionals do not check the devices used in a procedure beforehand properly to ensure the safety of the patient.
In the end, the medical negligence cases can be complicated and tricky and deciding whether a healthcare provider’s acts or omissions constitute negligence necessitates a comprehensive examination of the specific facts by legal and medical experts.
Essentials of Medical Negligence
1. There should be a legal obligation to care for the patient in the healthcare industry. The responsibility to properly give standard care for the patient and to deliver proper reasonable treatment by a qualified medical professional comes from a professional trust and connection in between the healthcare provider and the patient or patient party.
2. If by any chance there is a failure to offer the stipulated level of care by the healthcare practitioner, actions of conduct or actions of omission can be taken. The level of care is decided on the basis of the protocols of the particular healthcare as well as compared to the rest of the medical healthcare industry.
3. Causation: The violation or breach of duty must have been the result of the injury or the damage caused by the patient. Thus, in case of such injury on behalf of the health care provider, the patient must in fact show the direct casual connection that resulted in the adverse condition of the patient who was taken care by the said medical or healthcare professionals. Therefore must prove that under no conditions the patient’s injury could have taken place other than the conditions that happened due to the negligence of the healthcare vendor.
4. Damages: Thus, due to the damages caused by the medical healthcare professional’s negligence; the patient if proven, must be able to sustain all the losses from the medical professional in question as an compensation for their negligent act.
5. Proximate cause: The patient’s injury however should be reasonably anticipated consequence of the negligence caused by the healthcare professionals. The injury should be directly connected to the breach of duty and should be inevitable and probable effect of the healthcare provider’s omissions or conduct.
6. Statute of restrictions: If there are claims of medical malpractice then that needs to be submitted within a certain period of time known as the “period of limitations”. The statute of limitations might differ depending upon the location.
Indian Medical Council Act, 1956
The Act was implemented for the constitution of the present day Medical Council of India (MCI), the maintenance and regulation of a Medical Register, as well as all corresponding matters connected to it. Two amendments were made to this Act as of today – first in 1964 followed by 1993.
The MCI holds exclusive rights to grant recognition to any medical institutions, any -existing or upcoming – courses or specialized training to be implemented, as well as validate required qualification modifications that need to be made which are granted by the aforementioned Universities or medical institutions in India (Section 11, 12 and 13). It allows the registered medical personnel to practice allopathic therapy system (Section 15). The MCI has laid down the necessary guidelines which must be complied with for gaining national recognition, as well as for the maintenance of the standard of education provided (Sections 16-20). The Council has provided regulations for the “standards of professional conduct, etiquette and code of ethics”, which must be observed by the medical practitioners. These standards are to be followed with strict compliance and are deemed as mandatory for all other State Medical Councils (Section 33).
Sections 21-29 puts forth the entry of names in the register, removal of names as well as the restoration of the same. It also explains the maintenance of the registers, registration of additional personnel, and so forth.
The Indian Medical Council Regulations (Professional Conduct and Ethics) related to the professional conduct of the practitioners, the necessary ethics that need to be upheld, as well as the etiquette to be followed were notified in 2002. It can be described as per the following chapters.
Code of Medical Ethics
As per the Code of Medical Ethics, the physician must uphold the honour and dignity of their profession, with providing services to humankind being the prime aspect. Any form of rewards or incentives – monetary or otherwise – gained shall be deemed subordinate.
Only the individuals who have met the qualifications laid down in the modern allopathic system of medicine shall be permitted to practice the system of allopathic treatment.
The physician or the medical practitioner must always strive for continuous and progressive enhancement of their medical knowledge and improvement of their skills. They are required to affiliate themselves with reputed an allopathic organization, and must continue to attend medical educational programme, or a minimum of 30 hours per 5 years.
The practitioner must document and maintain contemporaneous records of their patients for 3 years, which should be presented at any given time of requirement. They are also required to maintain a medical certificate register which must contain all relevant and necessary information pertaining to the persona for whom the certificate has been issued.
The physician must display their registration number at their clinic as well as on every prescription, certificate, et cetera. They are required to display their recognized degree(s), diploma memberships and honors (if any), as a suffix to their name. They should rationally prescribe only generic names of the required therapeutic drugs ; and must display their consultation and visitation fees at their chamber. Their fees must be announced before any consultations with the patient – and not when the operation or therapeutic treatment has been ensued.
The physician must be cooperative when undergoing observations and enforcement of any sanitary laws and regulations that have been issued in interest of public health. They should observe and comply with any existing provisions of state Acts viz. Drugs and Cosmetic Act (1940), Medical Termination of Pregnancy Act (1971), Pharmacy Act (1948), Transplantation of Human Organs Act (1994), Narcotic Drugs and Psychotropic Substance Act (1985), Mental Health Act (1987), Drugs and Magic Remedies (Objectionable Advertisement) Act (1954), Prenatal Sex Determination Test Act (1994), Biomedical Waste (Management and Handling) Rule (1998), Persons with Disabilities (Equal Opportunities and Full Participation) Act (1995), and so forth.
Doctrines required in Medical Negligence:
Being a medical practitioner negligence is considered to be a failure or malpractice in accordance with the reasonable compatibility of a professional who studies the human body at the time of act occurrence. It could be possible there may or may not be one or more chances/ possibilities to save or cure that person, but if a doctor couldn’t perform a proper diagnosis or negligently uncared that patient or the person for which that person suffers huge/permanent loss even death then that act of the Medical practitioner should be liable of Medical Negligence.
However there is only one and only doctrine which could explains the act done by negligent of any person which causes accident, in legal maxim it is calls “res ipsa loquitur” taken from Halsbury’s Laws of England, which is nothing but a civil wrong which is explains in Law of Tort. Here the burden of proof lies on to the Plaintiff or the Complainant that weather there is any act of negligence by the other person for which he/she gets hurt, when there isn’t any direct evidence regarding the matter in the suit the plaintiff shall have to satisfy the Court there is ‘a circumstantial evidence’ which couldn’t happened if there isn’t any act of negligence or the guilty of mind in the said situation.
How is a Res ipsa loquitur case proven?
This maxim implies that the evidence speaks for itself. It demonstrates the negligence in the situation done by any doctor, any medical practitioner, or the medical council. By this notion, the court has to prove that negligence was caused by them. However, the doctor may deny the statement if there isn’t any proof of negligence or subsequent negligence while proving the treatment to the person. But if it is assumed that there is any establishment of medical misconduct, then immediately that doctor will be prosecuted under the following criminal laws in India.
Res ipsa loquitur (which is Latin for “the thing speaks for itself”) is nothing but proving the complainant’s statement through some circumstantial evidence and making it possible that the defendants in the lawsuit have done this malicious act with a clear intention to harm the plaintiff. Basically this doctrine is coined as the Rule of Evidence, but not the Rule of Law proved through the General Principals of Law.
Elements of Res ipsa loquitur:
There are basically three essential elements in the maxim:
- That the harm, the causes of damage, or the death could be under such a circumstance that it reflects the act of negligence and not a normal act.
- The defendant’s act must have been brought about through the use of his object, which was solely in the defendant’s hands, by which the plaintiff was harmed.
- The plaintiff’s harm must fall within the defendant’s purview of responsibility and cannot be attributable to the plaintiff’s own initiative or voluntary action.
If the first condition is satisfied in the doctrine there is a resonable posibility of assuming that the event could have occured if there isn’t any negligence on the defendant’s side. Though it is difficult to prove as the Plaintiff is always a layman in respect to the profession to prove the negligent act.
The components of medical negligence refer to the legal duty of care that a doctor has towards a patient; this duty may be the most significant factor at any stage of the relationship between a patient and a doctor. Generally, the idea of a legal obligation is that, in a socialized system, all individuals owe an obligation of due care to others. Based on this principle, if a doctor provides administration to a person, the doctor is obligated to provide them with appropriate care. A patient cannot hold a doctor responsible for a breach of their duty if the relationship between the two parties does not exist.
Medical Termination of pregnancy (MTP)
Medical Termination of pregnancy (MTP) has been sanctioned in India beginning around 1971 thinking about the tremendous weight of dangerous early terminations. Indeed, even after 50 years, Indian ladies kept on having dangerous early terminations and face antagonistic and lethal outcomes. As of now, just administrative revisions may not be adequate however alongside that, numerous different perspectives should be viewed as like mindfulness, accessibility, availability, moderateness of value MTP administrations, and contraceptives. Individuals ought to know the antagonistic impacts of taking unaided clinical end pills. Complete fetus removal care ought to be given at each degree of medical services to guarantee the great regenerative strength of the ladies.
MTP sanctioned on first April, 1971
1. Alterations or amendments of the act- 1975, 2003, 2014, 2020
2. Before these demonstration the pregnancies ended according to Indian Penal Code is drafted in 1860 during English rule (IPC).
3. Indian Penal Code > Initiated Early termination > Unlawful Prompted fetus removal implies deliberately unnatural birth cycle.
4. According to IPC punishments fetus removal professional 3 years detainment or fine or the two ladies 7 years detainment or fine or both
5. The embryo has the option to live according to MTP ACT 1971.
Offences and penalties
1. Anyone who fails to comply with rules made under the Act or contravenes them may be fined up to Rs. 1000/-
2. The arrangement by suggestion perceives that the hatchling has the option to life. At the point when the end of pregnancy is caused without the assent of the ladies, discipline might stretch out to detainment forever or detainment of all things considered portrayal for a term, which might reach out to 10 years or fine.
Medical negligence provisions in the Criminal Laws :
Medical malpractice can be established if it can be shown that a doctor or medical professional committed an act of negligence that may or may not have been motivated by recklessness with the intent to harm or that the doctor or medical professional was guilty of mind (i.e., Mens Rea) for harming his patient or victim. Such offenses may be tried and punished in accordance with the Indian Penal Code, 1860 (New Bill Name: Bharatiya Nyaya Sanhita 2023). In certain situations, the patient, the victim of medical malpractice, or any other family member (in the case of the deceased) will or should get permission under the modified Criminal Procedural Code, 1973 (New Bill Name: Bharatiya Sakshya Bill 2023). There are various sections and clauses that cover medical negligence under criminal law, as mentioned below.
There are a few clauses in the Indian Penal Code, 1860 which relate to medical negligence such as Section 52, 80, 81, 83, 88, 90, 91, 92, 304-A, 312, 336-339, and 345.
However, in accordance with Section 304A of the I.P.C., 1860, a person should be considered guilty of murdering another person if they commit any careless acts or act quickly enough to put another person in peril of dying. It should be noted that the action or omission in society that results in the person’s death must be a violation of Human Rights. In such circumstances, the judge may impose the highest penalty of two years in prison, a fine, or both.
Instead of these, there are other laws in India that could defend the injustice with regard to medical negligence such as
How to file a complaint against medical negligence in India?
Filling a complaint –
A practitioner of medical sciences has an obligation to fulfil. They process a reasonable degree of skill and care for their clients or patients. If a practitioner doesn’t fulfill his obligations, which amounts to causing injury to the patient, may face a complaint filed against him by the patient for not taking care or fulfilling the duty which was necessarily to done.
Procedure of filling a complaint –
- A complaint under medical negligence must be filed with local police through a FIR or state medical council.
- If it is filed only to the police the police can send the report of such complaint to the state medical council.
- The council will take cognizance of the complaint filed and find it seriously endangering the life of the patient, and then it can suspend the license of the medical practitioner for a relevant period of time.
- The court will examine the facts of the case referred by the state medical council under relevant sections.
- If the patient is not satisfied with the order of the court, he or she can make an appeal in the medical council of India.
- The consumer courts may provide compensation to the injured patient but cannot decide punishment for the guilty.
- If the complaint is not satisfied with the decision of the consumer court, he can approach the National Consumer Dispute Redresal Commission.
In the year 1995, the Supreme Court brought the medical profession under the Consumer Protection Act 1986 and medical treatments were labelled as services.
What doesn’t constitute medical malpractice?
It’s important to understand what kinds of treatments or circumstances at the hospital or healthcare institution aren’t regarded as medical malpractice while you’re attempting to determine whether you were the victim of it. It’s crucial to remember that complaints about the care you received are insufficient justification for alleging malpractice. You probably don’t have a claim if there wasn’t any carelessness or recklessness involved.
Medical malpractice may not be present when you see the doctor for treatment of a disease or injury and your doctor does everything within their power to treat you, but your condition either hasn’t improved or has become worse. It is not your doctor’s responsibility if your condition hasn’t improved if they done everything within their power and made no mistakes in diagnoses or treatments.
What are the rights availed to the Patients with regard to Medical Negligence?
As it is a consumer case filed under the Consumer Protection Act,1986. So just like every consumer should be notified about the risks and side effects of the treatment, they should be fully aware of what the treatment or the diagnosis is for, and they can ask about the possibilities of success regarding the diagnosis, the patient should know the qualifications of the doctor who is going to diagnose the patient, the patient should have a second opinion in case of any doubt if he or she couldn’t make any decision then any of the patient relatives or any other trustable person which is known to the patient could deliver the opinion regarding the matter, the patient can make any consultation by own. Patients have a right to be treated with respect and dignity when they’re seen by a doctor. They have a right to keep their medical information private and doctors should respect that. Patients have a right to get medical records/cases from the doctor or hospital when they need them. If they need to be transferred to a different hospital, they have a right to know why and decide after talking to the doctor. They can also get details on the bills they’ve paid.
The Supreme Court’s Judgement on medical negligence cases in India
There are a few renowned landmark cases in the Supreme Court as well as the High Court relating to medical negligence in India listed below:
- Dr. Kunal Saha Represented By Sri vs. Dr. Sukumar Mukherjee and Ors. SCC 384(2014)
It was a Landmark Case on medical negligence where a doctor couple namely Dr. Kunal Saha and Dr. Anuradha Saha who lived in the U.S. had come to Kolkata to attend a wedding ceremony. Here Dr. Anuradha Saha had observed a few rashes on her skin, and the couple was told by their friends to make an appointment with a prominent doctor named Dr. Sukumar Mukherjee. Here Dr. Mukherjee had negligently overdosed on the patient due to which the condition of the patient condition gets detoriated to worsen. Later in 2013 Supreme Court held that the Doctors and the AMRI hospital were liable for this negligent act and asked them to compensate a huge some of money. Later on, Dr. Kunal Saha filed an another petition regarding the promotion of the said doctors who were been prosecuted in this above case.
- Indian Medical Association v. V.P. Shantha 1996 AIR 550
This case laid the groundwork for the concept of ‘informed consent’, which is the requirement that a patient is adequately informed of the potential risks associated with a medical procedure prior to consenting to the procedure. According to the Supreme Court, a lack of informed consent by a patient constitutes medical negligence.
- Malay Kumar Ganguly vs. Dr. Sukumar Kumar Mukherjee and Ors. AIR 2010 SC 1162
In this particular case, the petitioner was injured as a result of a medical procedure that the respondent doctor performed. The petitioner sued the doctor, claiming he was negligent in his medical care and lost money. Whether the doctor may be held accountable for treating the petitioner negligently was the primary question in the case. The Supreme Court noted that a physician is required by law to disclose to a patient the relevant risks associated with a medical operation and to get the patient’s informed consent prior to performing the surgery. The court stated that it is medical negligence to neglect to disclose to a patient all relevant risks associated with a medical operation. The doctor was ordered to compensate the petitioner by the Supreme Court, which found the doctor responsible for the petitioner’s medical negligence during treatment. The Indian medical law’s informed consent principle was strengthened by this case.
Further Cases this Medical Negligence
- V. Kishan Rao vs. Nikhil Super Speciality Hospital (2010) 5 SCC 513
- Jacob Mathew vs. State of Punjab (2005) 6 SCC 1
- Juggan Khan vs. State of Madhya Pradesh AIR 1965 SC 831
- A.S. Mittal and Others vs. State of U.P. and Others 1989 AIR 1570
- Poonam Verma vs. Ashwin patel and Others 1996 AIR 2111
- M/S Spring Meadows Hospital and another v Harjol Ahluwalia 1998(2) SC 456
- Bhalchandra Alias Bapu & Another v. State of Maharashtra 1968 AIR 1319
What are the directions/precautions stated by the Supreme Court to Medical Professionals:
In the judgment in Martin F.D.Souza vs Mohd.Ishfaq 2009 3 (SCC 1), the apex court held that the appellant was not qualified to prescribe or provide treatment to the respondent and directed the medical board/institution/hospitals/nursing homes/doctors that :
- To strictly supervise every device, infrastructure, and paramedic, including the qualification of the doctor regarding the practice, and other staff.(1)
- To ensure that every instrument is properly sterilized and maintained proper hygiene.
- No prescription is permitted by any doctor without an actual examination, including on the telephone, if it is not an emergency.
- A doctor should not only agree with the patient’s statement of symptoms/disease but should also conduct research, including tests/other tests, and draw conclusions concerning the probability of cure if needed.
- A doctor should not experiment on anyone’s body even if the patient has given written consent. A doctor/ hospital/ nursing home should maintain a complete report of diagnosis/treatment. A doctor should consult their senior authority/any expert member/members in case required(2)
Thereafter, Medical Negligence is the black spot in the development of medical science. Though every situation of failure during treatment does not come under the purview of negligence, the problem of medical negligence is very much prevalent in every type of healthcare unit. The basic difference between medical Negligence and normal failure of treatment is that in case of medical Negligence, there remains a lack of care and breach of duty.
Clinical carelessness is an intricate issue, and it requires a multi-layered way to deal with it. The lawful structure, joined with moral rules and patient’s mindfulness, can assist with guaranteeing that patients get the most ideal clinical consideration and that clinical experts are considered responsible for their activities.
It is pivotal for clinical experts to know about their lawful and moral commitments and for patients to be educated regarding their privileges to guarantee that clinical consideration is given in a mindful and responsible way. At last, the objective of the lawful system for clinical carelessness in India is to guarantee that patients get protected and powerful clinical consideration that maintains their poise and prosperity.
- (Dr. Kunal Saha Represented By Sri vs. Dr. Sukumar Mukherjee and Ors. , 2014)(Indian Medical Association v. V.P. Shantha , 1996) (Malay Kumar Ganguly vs. Dr. Sukumar Kumar Mukherjee and Ors. AIR 2010 SC 1162, AIR 2010)(Stratton versus Swanlond, 1982 Fall;45(4):20-4., 1982)(V. Kishan Rao vs. Nikhil Super Speciality Hospital 5 SCC 513, 2010)(Jacob Mathew vs. State of Punjab (2005) 6 SCC 1, 2005)(Juggan Khan vs. State of Madhya Pradesh AIR 1965 SC 831, AIR 1965)(A.S. Mittal and Others vs. State of U.P. and Others 1989 AIR 1570, 1989)(Poonam Verma vs. Ashwin Patel and Others , 1996)(M/S Spring Meadows Hospital and another v Harjol Ahluwalia 1998(2) SC 456, 1998(2)) (Bhalchandra Alias Bapu & Another v. State of Maharashtra 1968 AIR 1319, 1968)(Martin F.D. vs Mohd.Ishfaq 2009 3 (SCC 1), 2009)(Sarwat Ali Khan v. Prof. R. Gogi (OP No. 181 of 1997), 1997)(Indrani Bhattacharjee , 1996),
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