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MEDICAL
PROFESSION
IN
THROUGH
JUDICIALMICROSCOPE
(AN ABRIDGED VERSION OF THE
RESEARCH PAPER)
Adv.
C.K.SIVADASAN
M.A.(PMIR), LL.B., PGDADR(NALSAR).PGDT., DACT. ,DEM. ,C.Coun,
CONSULTANT
(Medico-Legal
& Hospital Administration)
Email:cksdas@yahoo.co.in
-----------------------------------------------------
MEDICAL
PROFESSION IN
“Medical profession is one of the oldest
professions of the world and is the most humanitarian one. There is no better
service than to serve the suffering, wounded and the sick. Inherent in the
concept of any profession is a code of conduct, containing the basic ethics
that underline the moral values that govern professional practice and is
aimed at upholding its dignity. Medical Ethics underpins the values at the
heart of the practitioner-client relationship. In the recent times,
professionals are developing a tendency to forget that the self-regulation
which is at the heart of their profession is a privilege and not a right and
a profession obtains this privilege in return for an implicit contract with
society to provide good, competent and accountable service to the public. It
must always be kept in mind that doctor’s is a noble profession and the aim
must be to serve humanity, otherwise this dignified profession will lose its
true worth.” [State of
Reasonable
expectation
While
undergoing treatment, what is the nature of relationship between a doctor and
a patient? Or in other words, what are the reasonable expectations of the
patient regarding the duties of the doctor towards him? This question is
answered in the case of
The standard of duty to care in medical
services is explained in detail in the case of Dr. Laxman Balakrishna Joshi vs Dr. Trimbak
Bapu Godbole, (Supreme Court of
India, 1969), Achutrao
Haribhau Khodwa vs. State of Maharashtra, (Supreme Court of India, 1996) and Malay Kumar Ganguly vs. Sukumar Mukherjee, (Supreme Court of India, 2009).
Much more to this, in the case of State of Punjab vs. Shiv Ram, (Supra), their Lordships analyzed old treatises and
customs and held that medical profession has long subscribed to a body of
ethical statements developed primarily for the benefit of the patient. This
basic principle comes from Hippocrates, the “Father of Medicine”, who formulated a code of conduct in the form
of the “Hippocratic Oath”. Based
on his perception that, knowledge and skill were not enough for a physician
without a code of standards and ideals he coined an oath of integrity for
physicians. A code of standards and ideals to which they must swear to adhere
in the practice of their profession. This continues till date to be the oath
administered to doctors when they join the profession.
Bolam’s test
The test of medical negligence which was laid
down in Bolam vs.
Prior to the treatment of electro-convulsive therapy at the defendant’s
hospital, Bolam signed a form of consent to the treatment but was not warned
of the risk of fracture involved. Even though the risk was very small, but
when the treatment was repeated for the second time he sustained fractures.
No relaxant drugs or manual control were used. About this treatment there
were two bodies of opinion, one of which favoured the use of relaxant drugs
or manual control as a general practice, and the other opinion was for the
use of drug that was attended by mortality risks and confined the use of
relaxant drugs only to cases where there are particular reasons for their use
and Bolam’s case was not under that category. The Court held the doctors were
not negligent based on the findings that while dealing with a situation, in
which special skill is the necessity, the test is the standard of the
ordinary skilled man exercising and professing to have that special skill. A
man need not possess the highest expert skill.
These principles are accepted in Jacob Mathew vs. State of
Even though Bolam’s test was accepted by Courts in India measuring the
standard norms in cases of medical negligence, in the country of its origin,
it has been found that the inherent danger in Bolam’s test is that if the
courts defer too readily to expert evidence, medical standards would
obviously decline. (Ref: Medical Negligence by Michael Jones, 4 Ed. 2008). In
the case of V. Kishan Rao vs. Nikhil Super Specialty Hospital, (2010), Supreme Court of India observed
that, “Opinion was gaining ground in
In Malay Kumar Ganguly vs. Sukumar Mukherjee, (2009), Supreme Court of India held that the Bolam’s case in common laws
jurisdictions is weakened in recent years by reasons of series of decisions
viz. Rogers vs. Whitaker
(Australia); Roenbreg vs. Percival;
Ribl vs. Hughes (Canada); Bolitho vs. City and Hackney Health
Authority and in the United States and even in the United Kingdom.
What is
Negligence
“Negligence is the breach of a duty caused by the omission to do
something which a reasonable man, guided by those considerations which
ordinarily regulate the conduct of human affairs would do, or doing something
which a prudent and reasonable man would not do.” [Law of Torts, Ratanlal
& Dhirajlal, 24th Ed.] Based on the above quoted definition
and the decision in R. vs. Adomako,
1994 (3) All E. R. 79, the
Honourable Supreme Court in the case of Dr.
Suresh Gupta vs. Govt. of N.C.T. of Delhi, (2004) declared the nature of medical negligence
is that where a patient dies due to
the negligent medical treatment of the doctor, the doctor can be made liable
in civil law for paying compensation and damages in tort. Meanwhile, if the
degree of negligence is so gross and his act was reckless as to endanger the
life of the patient, he would also be made criminally liable for offence
under section 304A of IPC. For fixing criminal liability on a doctor or
surgeon, the standard of negligence required to be proved should be so high
as can be described as ‘gross negligence or recklessness’. It is not merely
lack of necessary care, attention and skill.
Their Lordships of the Honourable Supreme Court of India again dwelt
into this subject in detail, and measured it on the basis of Bolam’s
principle and other decided cases including, R. vs. Lawrence, [1981] 1 All ER 974 (HL); R. vs. Caldwell 1981(1) All
ER 961 (HL); Andrews vs. Director of Public Prosecutions, [1937] A.C. 576,
in the case of Jacob Mathew vs. State Of Punjab (Supreme Court of India, 2005) and said: “A medical practitioner faced with an emergency ordinarily tries his
best to redeem the patient out of his suffering. A surgeon with shaky hands
under fear of legal action cannot perform a successful operation and a
quivering physician cannot administer the end-dose of medicine to his
patient. To prosecute a medical professional for negligence under criminal
law it must be shown that the accused did something or failed to do something
which in the given facts and circumstances no medical professional in his
ordinary senses and prudence would have done or failed to do.”
Meanwhile, dealing with a civil case [Nizam Institute of Medical Sciences vs. Prasanth S. Dhananka, (Supreme Court of India, 2009)], Court
held as under :- “We are also
cognizant of the fact that in a case involving medical negligence, once the
initial burden has been discharged by the complainant by making out a case of
negligence on the part of the hospital or the doctor concerned, the onus then
shifts on to the hospital or to the attending doctors and it is for the
hospital to satisfy the Court that there was no lack of care or diligence.”
In the cases of Dr. Laxman Balakrishna Joshi vs. Dr. Trimbak Bapu Godbole, (Supra
- use of excessive
force caused death due to shock); Nihal
Kaur vs. Director, P.G.I.M.S.R. (CDRC 1996 - relatives found a pair of scissors utilized by the
surgeon in the last remains of deceased); Spring
Meadows Hospital vs. Harjol Ahluwalia, (Supreme Court of India, 1998 - high
dose medicine injected caused brain damage), the Court held medical
professionals negligent.
Medical Profession &
Consumer Act
Before
the enactment of the Consumer
Protection Act, 1986, civil cases related with the medical profession are
dealt under the Laws of Contract and/or the Law of Torts. After the
enactment, different courts expressed different opinions regarding
applicability of provisions of the Consumer Protection Act to the medical profession, leaving
chaos and ambiguity on the matter. Considering appeals of different verdicts
of different courts, the Honourable Supreme Court of India declared the legal
position of the subject, after analyzing various issues raised by the
stakeholders of the profession, in the case of Indian Medical Association
vs. V.P. Shantha & Ors. (Supreme Court of India, 1996).
The following are the main issues raised by the parties against the
application of the Consumer Protection Act to the said profession:
(1) Medical practitioners are governed by the
provisions of the Indian Medical Council Act, 1956 and the Code of Medical
Ethics made by the Medical Council of India, which provides for disciplinary
action by the Medical Council of India and/or State Medical Councils against
a person for professional misconduct. As per the provisions of the Consumer
Protection Act, the deficiency with regard to fault, imperfection,
shortcoming or inadequacy in respect of service has to be ascertained on the
basis of certain norms relating to quality, nature and manner of performance
and that medical services rendered by a medical practitioner cannot be judged
on the basis of any fixed norms.
Referring, the distinction between a profession and an occupation, the
provisions of the Indian Medical Council Act, 1956 and the Code of Medical
Ethics made by the Medical Council of India and the decisions in the cases, Commissioners of Inland Revenue vs. Maxse,
1919 1 K.B. 647; Saif Ali vs. Sidney
Mitchell & Co., (1980) 1 A.C. 198; Rees
vs. Sinclair (1974) 1 N.Z.L.R. 180; Giannarelli vs. Wraith (1988) 81 A.L.R. 417, the
Court said, “The fact that they are
subject to the disciplinary control of Medical Council of India and/or State
Medical Councils is no solace to the person who has suffered due to their
negligence and the right of such person to seek redress is not affected”.
Regarding the second part of the contention, after referring, Whitehouse vs. Jordan, 1981 (1) WLR 246;
Maynard vs. West Midlands Regional Health Authority, 1984 (1) WLR 634;
Sidaway vs. Governors of Bethlem Royal Hospital, 1985 AC 871 and Dr. Laxman Balakrishna Joshi vs.
Dr.Trimbak Bapu Godbole, (Supreme
Court of India, 1969), held that “In view of the definition of ‘deficiency’ as contained in Section
2(1)(9) medical practitioners must be treated to be included from the ambit
of the Act and the service rendered by them is covered under Section 2(1)(o)
of the Consumer Protection Act, 1986”.
(2) The composition of the Consumer Disputes
Redressal Agencies is such that they cannot fully appreciate the complex
issues which may arise for determination and further that the procedure that
is followed by these bodies for determination of issues before them is not
suitable for the determination of the complicated questions which arise in
respect of claims for negligence in respect of the services rendered by
medical practitioners.
After analyzing various authorities, like Prof. Robin C.A. White (The
Administration of Justice, 2nd Ed.), and provisions and procedures, the
Honourable Court rejected it and said that “Various Foras, as per Act, combines with legal competence and the
merits of lay decision making by members having knowledge and experience in
dealing with problems relating to various fields which are connected with the
object and purpose of the Act, and it is not relevant to say that since the
members of the Consumer Disputes Redressal Agencies are not possessed with
knowledge and experience in medicine, they are not in a position to deal with
complaints about the deficiency in service rendered by medical
practitioners”.
(3) The procedure which is followed for
determination of consumer disputes under the Act is summary in nature
involving trial on the basis of affidavits and is not suitable for
determination of complicated questions requiring evidence of experts.
Regarding such contention the Court observed that there may be cases
which do not raise such complicated questions and the deficiency in service
may be due to obvious faults which can be easily established, such as removal
of the wrong limb, etc. The issues arising in the complaints in such cases
can be speedily disposed of by the Consumer Disputes Redressal Agencies and
there is nothing to prevent the Agencies from adjudicating such complaints.
(4) The relationship between a medical practitioner
and the patient is of trust and confidence and, therefore, it is in the
nature of a contract of personal service.
The Honourable Court referred decisions in Simmons vs. Heath Laundry Co. (1910) 1 K.B. 543 and Dharangadhara Chemical Works Ltd. vs.
State of Saurashtra, (Supreme Court
of India, 1957) and clarified that “The relationship between a medical practitioner and a patient
carries within it certain degree of mutual confidence and trust and,
therefore, the services rendered by the medical practitioner can be regarded
as services of personal nature but since there is no relationship of master
and servant between the patient and the doctor, the contract between the
medical practitioner and his patient cannot be treated as a ‘contract of
personal service’ but is a ‘contract for services’.”
(5) If medical practitioners are brought within the
purview of the Consumer Act the consequence would be huge increase in medical
expenditure on account of insurance charges as well as tremendous increase in
defensive medicine and that medical practitioners may refuse to attend to
medical emergencies and there will be no safeguards against frivolous and
vexatious complaints and consequent blackmail.
On this contention Their Lordships reached a conclusion after
analyzing various statistical data in
In Spring
Meadows Hospital vs. Harjol Ahluwalia, (Supra), the Court appreciated Consumer Commission, in
awarding compensation and damages to the parents for mental agony and expenses
for caring and treatment as well as to the child, in different heads, for the
negligence, by considering both of them as “consumers” in the same case.
Expert opinion
In many cases related with the medical
profession, before the Consumer Disputes Redressal Agencies it is contended
by the medical professionals, that the opinion of the experts is very
essential to decide cases against them, because of the complexity of the
subject and judiciary is not represented by any medical professionals. The
Honourable Supreme Court unequivocally declared the law in this subject in
the case of V.Kishan Rao vs. Nikhil Super Speciality Hospital (Supra), after referring previous decision in Malay Kumar Ganguly vs. Sukumar Mukherjee (Supra)
and held that “Whenever any of the
parties wants to adduce expert evidence before the consumer Fora, the members
of the Fora can allow the parties to adduce such evidence if it is
appropriate to do so, based on the facts of each case and there cannot be a
mechanical or strait jacket approach that each and every case must be
referred to experts for evidence. An expert witness in a given case normally
discharges two functions. Duty to explain the technical issues as clearly as
possible and to assist the Fora in deciding whether the acts or omissions of
the medical practitioners or the hospital constitute negligence. In doing so,
the expert can throw considerable light on the current state of knowledge in
medical science at the time when the patient was treated.”
Discovery Rule
While conducting surgery if the surgeon had
left a sponge in the patient’s body and it has identified after a long period
of the date of surgery, on which the right to sue may get exhausted as per
the Law of Limitation. From which date the cause of action be reckoned – the
date of first surgery or the date on which, the problem identified later?
This question is answered by the Honourable Supreme Court, after referring
various decided cases [Ayers vs. Morgan
(Pennsylvania); Morgan vs. Grace Hospital Inc. (West Virginia); Billings vs.
Sisters of Mercy of Idaho (Idaho); Josephine Flanagan vs. Mount Eden General
Hospital LEXSEE 24 N.Y. 2d 427 and declared the following rule: “Where a foreign object is negligently
left in a patient’s body by a surgeon and the patient is in ignorance of the
fact, and consequently of his right of action for malpractice, the cause of
action does not accrue until the patient learns of, or in the exercise of
reasonable care and diligence should have learned of the presence of such
foreign object in his body.” [V.N.Shrikhande vs. Anita Sena Fernandes, (Supreme Court of India, 2011)]
Dealing with criminals
To what extent the doctor is criminally
responsible for his assistance to a criminal, when a criminal or his relative
requests for treatment of the injuries of the criminal without informing the
real nature of incidence to the doctor? Supreme Court of India gave answer to
this question through the verdict of Suresh
Budharmal Kalani @ Puppu Kalani vs.
State of
Professional
obligation
What are the professional obligations of a
medical practitioner towards the society? In a case [Pt.Parmanand Khatara vs. UOI &Ors. (1989)], related with this subject the Supreme Court referred the
Code of Medical Ethics drawn up with the approval of the Central Government
under Section 33 of the Indian Medical Council Act, the decisions of the
Committee under the Chairmanship of the Director-General of Health Services
on this subject and the affidavit submitted by Indian Medical Council and
observed:
“(1) Article 21 of the Constitution casts the
obligation on the State to preserve life.
(2) There can be no second opinion that
preservation of human life is of paramount importance. That is so on account
of the fact that once life is lost, the status quo ante cannot be restored as
resurrection is beyond the capacity of man.
(3) The patient whether he be an innocent
person or a criminal liable to punishment under the laws of the society, it
is the obligation of those who are in-charge of the health of the community
to preserve life so that the innocent may be protected and the guilty may be
punished. Social laws do not contemplate death by negligence to tantamount to
legal punishment.
(4) Every doctor whether at a Government
hospital or otherwise has the professional obligation to extend his services
with due expertise for protecting life.
(5) No law or State action can intervene to
avoid/delay the discharge of the paramount obligation cast upon members of
the medical profession. The obligation being total, absolute and paramount,
laws of procedure whether in statute or otherwise which would interfere with
the discharge of this obligation cannot be sustained and must, therefore,
give way.”
Sterilization
In State
of
Blood transfusion cases
In Postgraduate Institute
of Medical Education and Research, Chandigarh vs. Jaspal Singh, (Supreme Court of India, 2009), the Court held that mismatch in transfusion of
blood resulting in death of the patient, after 40 days, is a case of medical
negligence. Though the learned Judges have not used the expression res ipsa loquitur, but a case of
mismatch in blood transfusion is one of the illustrations given in various
textbooks on medical negligence to indicate the application of res ipsa loquitur. [Ref: Quinton vs.
Consumer Disputes Redressal Commission in
the case of M. Chinnaiyan vs.
Eye operation camps
In A. S.
Mittal vs. State of U.P. (Supreme
Court of India, 1989), and in Sarwat
Ali Khan vs. Prof. R. Gogi (NCDRC 2007), the eyes of several patients
were irreversibly damaged after operation in camps, owing to post-operative
infection. The doctors were held liable.
Liability of
hospitals
Referring the cases, Collins vs. Hertfordshire County Council; Cassidy
vs. Ministry of Health [1951]; Gold & Ors. vs. Essex County Council
[1942] and R vs. Yogasa Karan [1990] the Honourable Court Savita Garg (Smt.) vs. Director, National
Heart Institute, (Supreme Court of
India, 2004), observed that
“In a case involving medical negligence, once the initial burden has been
discharged by the complainant by making out a case of negligence on the part
of the hospital or the doctor concerned, the onus then shifts on to the
hospital or to the attending doctors and it is for the hospital to satisfy
the Court that there was no lack of care or diligence”. Again, in Prof. P.N. Thakur vs.
Importance
of Consent in Treatment
Whether informed consent of a patient is necessary for surgical
procedure involving removal of reproductive organs? If so what is the nature
of such consent? When a patient consults a medical practitioner, whether
consent given for diagnostic surgery, can be construed as consent for
performing additional or further surgical procedure – either as conservative treatment or as
radical treatment – without the specific consent for such additional or
further surgery. Whether there is a possibility of the treating Doctor to
falsely invent a case that the patient was suffering from a chronic condition
to explain the unauthorized and unwarranted surgery or procedure or to
cover-up negligence in conducting diagnostic procedure or to claim a higher
fee? Even if the patient was suffering from chronic condition but without
immediate danger to life, whether the Doctor’s decision to perform radical
surgery instead of conservative treatment/surgery is valid? Whether the
Doctors are guilty of the tortious act of negligence/battery by doing
procedures without consent? These questions came to the Supreme Court of
India for decision in the case of
Samira Kohli vs. Dr.Prabha Manchanda & Anr.(2008). The honourable
court analyzed various treatises viz. Principles of Medical Law (published by
Oxford University Press -- Second Edition, edited by Andrew Grubb and the
Code of Medical Ethics laid down by the Medical Council of India and
interpreted the law in this regard relying on previous decisions viz. Schoendorff vs. Society of New York Hospital - (New
York 1914); Murray vs. McMurchy
(Canada 1949); Marshell vs. Curry (Canada 1933); Achutrao Haribhau Khodwa vs.
State of Maharastra (Supreme Court of India, 1996); Vinitha Ashok vs. Lakshmi Hospital (Supreme Court of
India,2001) and held:
“(i) A doctor has to seek and secure the
consent of the patient before commencing a ‘treatment’ (the term ‘treatment’
includes surgery also). The consent so obtained should be real and valid,
which means that: the patient should have the capacity and competence to
consent; his consent should be voluntary; and his consent should be on the
basis of adequate information concerning the nature of the treatment
procedure, so that he knows what is consenting to.
(ii) The ‘adequate information’ to be
furnished by the doctor (or a member of his team) who treats the patient,
should enable the patient to make a balanced judgment as to whether he should
submit himself to the particular treatment as to whether he should submit
himself to the particular treatment or not. This means that the Doctor should
disclose (a) nature and procedure of the treatment and its purpose, benefits
and effect; (b) alternatives if any available; (c) an outline of the
substantial risks; and (d) adverse consequences of refusing treatment. But
there is no need to explain remote or theoretical risks involved, which may
frighten or confuse a patient and result in refusal of consent for the
necessary treatment. Similarly, there is no need to explain the remote or
theoretical risks of refusal to take treatment which may persuade a patient
to undergo a fanciful or unnecessary treatment. A balance should be achieved
between the need for disclosing necessary and adequate information and at the
same time avoid the possibility of the patient being deterred from agreeing
to a necessary treatment or offering to undergo an unnecessary treatment.
(iii) Consent given only for a diagnostic
procedure, cannot be considered as consent for therapeutic treatment. Consent
given for a specific treatment procedure will not be valid for conducting
some other treatment procedure. The fact that the unauthorized additional
surgery is beneficial to the patient, or that it would save considerable time
and expense to the patient, or would relieve the patient from pain and
suffering in future, are not grounds of defence in an action in tort for
negligence or assault and battery. The only exception to this rule is where
the additional procedure though unauthorized, is necessary in order to save
the life or preserve the health of the patient and it would be unreasonable
to delay such unauthorized procedure until patient regains consciousness and
takes a decision.
(iv) There can be a common consent for diagnostic and
operative procedures where they are contemplated. There can also be a common
consent for a particular surgical procedure and an additional or further
procedure that may become necessary during the course of surgery.”
Denial of emergency aid
Referring to Khatri (II)
vs. State of Bihar, (Supreme
Court of India, 1981); Rudul Shah vs.
State of Bihar, (Supreme Court of India, 1983);
Nilabati Behra vs. State of Orissa, (Supreme Court of India, 1993); Consumer Education and Rasearch Centre vs.
Union of India (Supreme Court of India, 1995), the Supreme Court in Paschim Banga Khet Mazdoor Samity vs. State of West Bengal (1996),
held that “In the context of the
constitutional obligation to provide free legal aid to a poor accused on
account of financial constraints, the denial of emergency aid to the
petitioner due to the non availability of bed in the Government Hospital
amounts to the violation of the right to life under Article 21 of the
Constitution and liable to pay compensation.”
Govt
hospitals & Consumer
Act
In Indian
Medical Association vs. V.P. Shantha (Supra), their Lordships have gone to the extent that even if the
doctors are rendering services to the patients free of charge in the
Government hospitals, the provisions of the Consumer Protection Act will
apply, after analyzing, the definition of ‘service’ given in Section 2(1)(o)
of the Consumer Protection Act, 1986, and have observed that the position
related with the services provided in the Government hospitals as:
“Service rendered at a Government
hospital/health centre/dispensary where no charge whatsoever is made from any
person availing the services and all patients (rich and poor) are given free
service - is outside the purview of the expression ‘service’ as defined in
Section 2(1) (o) of the Act. The payment of a token amount for registration
purpose only at the hospital/nursing home would not alter the position.
Service
rendered at a Government hospital/health centre/dispensary where services are
rendered on payment of charges and also rendered free of charge to other
persons availing such services would fall within the ambit of the expression
‘service’ as defined in Section 2(1) (o) of the Act irrespective of the fact
that the service is rendered free of charge to persons who do not pay for
such service. Free service would also be ‘service’ and the recipient a
‘consumer’ under the Act.”
ESI Corporation
& Consumer Act
In Kishore
Lal vs. Chairman, ESIC, (Supreme Court of India, 2007), the Court referred decisions in Indian Medical Association (supra); Spring Meadows Hospital vs. Harjol Ahluwalia,
(Supra); State of Karnataka vs. Vishwabharathi House Building Co-op.
Society, (Supreme Court of India, 2003);
Secretary Thirumurugan Co-operative Agricultural Credit Society vs. M.Lalitha
(Supreme Court of India, 2004)
and the provisions of the ESI Act, 1948, and held that “The service rendered by the medical practitioners of
hospitals/nursing homes run by the ESI Corporation cannot be treated as
gratuitous, because the charges for consultation, diagnosis and medical
treatment are borne by the insurer and the claim for damages for negligence
would not fall within the purview of the Employee’s Insurance Court, such
service would fall within the ambit of ‘service’ as defined in Section
2(1)(o) of the Consumer Act.”
Hospitals run by
the employer
In the case of Laxman
Thamappa Kotgiri vs. G.M. Central Railway, (Supreme Court of India, 2005), where an employee of the
railways had filed a complaint on the ground that his wife had been
negligently treated at a hospital of the Central Railway as a result of which
she died. The Honourable Court held that
“Since the medical treatment in the said Hospital is given to employees and
their family members is part of the conditions of employment and that the
Hospital is run and subsidised by the employer, the appellant’s case would
fall within the parameters laid down in paragraph 55(12) of the judgment in V.P. Shantha’s case and in Section
2(1)(o) of the Consumer Act.”
While concluding
this, even though it is inconclusive, we have to look into two important
verdicts related with this subject. In State of
Again,
their Lordships, in the case of Martin F.D’ Souza vs. Mohd. Ishfaq,
(Supra), laid down Precautions which
Doctors/Hospitals/Nursing Homes should take and held “It is true that the medical profession has to an extent become
commercialized and there are many doctors who depart from their Hippocratic
Oath for their selfish ends of making money. However, the entire medical
fraternity cannot be blamed or branded as lacking in integrity or competence
just because of some bad apples”
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Tuesday, 17 June 2014
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