Forensic Medicine · Consent, Professional Negligence and Medical Ethics (Consumer Protection, Vicarious Liability)

A surgeon performs laparoscopic cholecystectomy and inadvertently clips the common bile duct. The patient develops obstructive jaundice requiring re-operation. Assuming the surgeon followed a standard technique and the clip placement was within the range of acceptable surgical variance, this outcome is MOST accurately classified as:

  • A Medical negligence because harm resulted from the procedure
  • B Absolute liability because CBD injury is entirely preventable
  • C A recognised complication that does not per se constitute negligence; additional proof of deviation from standard of care is required
  • D Criminal negligence under Section 304A BNS as recklessness can be presumed
Correct answer: C. A recognised complication that does not per se constitute negligence; additional proof of deviation from standard of care is required

Explanation

A recognised complication occurring at an accepted rate does not by itself constitute negligence. The legal test in India (following the Bolam test — affirmed in Jacob Mathew vs State of Punjab, 2005 Supreme Court) requires proof that the doctor deviated from the standard of care a reasonably competent doctor in the same specialty would have exercised. Complications inherent to a procedure, even causing serious harm, do not establish negligence without evidence of technical error or failure to warn. Criminal negligence (Section 304A) requires gross negligence far exceeding ordinary civil negligence.

Reference: The Essentials of Forensic Medicine and Toxicology (Narayan Reddy), 34th ed.

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