Introduction
The Supreme Court of India, in Deep Nursing Home and Another v. Manmeet Singh Mattewal and Others (2025 INSC 1094), delivered on 9 September 2025, clarified an important principle of consumer jurisprudence that adjudicatory forums cannot travel beyond the pleadings of the parties and invent a new case altogether. This ruling not only reiterates judicial discipline in consumer disputes but also underscores the scope and limits of liability in cases of alleged medical negligence. The Court set aside concurrent findings of the State Consumer Disputes Redressal Commission (SCDRC) and the National Consumer Disputes Redressal Commission (NCDRC), which had earlier held doctors and the nursing home liable in varying degrees.
Table of Contents
- Introduction
- Factual Background
- Proceedings before SCDRC
- NCDRC's Findings
- Medical Board Reports
- Supreme Court's Analysis
- Final Judgment
- Conclusion and Author's Opinion
Factual Background
The case arose out of a tragic incident wherein the complainant, Manmeet Singh Mattewal, lost his wife, Charanpreet Kaur, and their newborn child within a span of hours during delivery at Deep Nursing Home, Chandigarh. Charanpreet Kaur, aged 32, was admitted on 21 December 2005. The newborn died immediately after delivery, and the mother succumbed a few hours later due to atonic Post Partum Haemorrhage (PPH). The complainant alleged that the nursing home was inadequately equipped to handle obstetric emergencies, that blood was not arranged in time, and that negligence in post-delivery care caused the death. Compensation of ₹95,21,000/- was sought before the SCDRC.
Proceedings before SCDRC
On 31 January 2007, the SCDRC held Deep Nursing Home and Dr. Kanwarjit Kochhar negligent for failing to exercise due care in post-delivery management of the patient. While exonerating them of negligence in relation to the death of the newborn, the Commission awarded ₹20,26,000/- in compensation, directing New India Assurance Company to pay ₹20,00,000/- and the balance by the nursing home and doctor. Interest at 9% and costs of ₹10,000 were also imposed. he SCDRC went further, doubting the presence of Dr. G.S. Kochhar during transfer of the patient to PGI, terming his affidavit fabricated, and concluded that the body was shifted merely to dump it at PGI.
NCDRC's Findings
Both the nursing home and Dr. Kochhar appealed before the NCDRC. Surprisingly, the NCDRC shifted the entire liability onto Dr. Kochhar, relieving the nursing home and insurer. More critically, while acknowledging that no negligence was proved in delivery, post-delivery care, or newborn management, the NCDRC held Dr. Kochhar negligent in antenatal management, specifically for not prescribing haematological and cardiological tests. This finding not only went beyond the complainant's pleadings but also turned the complainant's original case on its head, since the very allegations of negligence in delivery and post-delivery care were rejected by the NCDRC itself.
Medical Board Reports
The case was extensively scrutinised by five independent Medical Boards, all constituted on the complainant's request. Except for one report that left open the possibility of pre-existing anaemia or cardiac complications, every report concluded there was no gross medical negligence in the treatment provided. The Supreme Court noted that these reports, obtained at the complainant's own behest, carried decisive weight in exonerating the doctors.
Supreme Court's Analysis
The Supreme Court categorically held that the NCDRC had transgressed its jurisdiction by creating a new case of antenatal negligence, contrary to pleadings. The complainant never alleged deficiency in antenatal care; in fact, he specifically admitted that tests were prescribed and undertaken. Once the NCDRC itself found no negligence in delivery or post-delivery management, the complainant's case effectively collapsed. By constructing an entirely new ground of liability, the NCDRC overstepped its powers.
The Court relied upon established principles laid down in Trojan & Co. v. Nagappa Chettiar (1953) 1 SCC 456 and Ram Sarup Gupta v. Bishun Narain Inter College (1987) 2 SCC 555, which held that no decision can be based on grounds outside the pleadings, and parties cannot be taken by surprise. More recent judgments such as A.V.G.P. Chettiar & Sons v. T. Palanisamy Gounder (2002) 5 SCC 337 and Venkataraman Krishnamurthy v. Lodha Crown Buildmart (P) Ltd. (2024) 4 SCC 230 were also cited to reinforce that adjudicatory bodies cannot exceed the contours of pleadings.
Final Judgment
The Supreme Court allowed the appeal, setting aside the orders of both the NCDRC and SCDRC. Complaint Case No. 56 of 2006 was dismissed in its entirety. Importantly, the Court directed the complainant, Manmeet Singh Mattewal, to refund ₹10,00,000/- received during the course of litigation. The amount is to be repaid in ten monthly instalments of ₹1,00,000 each, with ₹3,00,000 payable to New India Assurance Company and the balance ₹7,00,000 to Dr. Kanwarjit Kochhar and Dr. G.S. Kochhar. As the nursing home no longer exists, the payment is to be made directly to the doctors. Each party was directed to bear its own costs.
Conclusion and Author's Opinion
This ruling is significant not only for medical professionals but also for consumer law jurisprudence. The Supreme Court rightly emphasised that while courts and consumer fora have a duty to protect patients from genuine negligence, they must refrain from donning the role of medical experts or reconfiguring a case beyond pleadings. Doing so compromises the fairness of proceedings and undermines the principle of natural justice.
In the author's view, the judgment strikes an essential balance after acknowledging the tragedy faced by the complainant, yet upholding the foundational principle that liability cannot be fastened on grounds never pleaded or proved. By reinforcing the sanctity of pleadings and expert opinion, the Court has ensured that consumer justice remains fair, principled, and legally sound. This case is a vital precedent for preventing overreach by consumer forums and will guide future adjudication in medical negligence cases.
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