The Supreme Court has quashed criminal proceedings initiated against an anaesthetist accused of medical negligence in connection with the death of a patient following piles surgery, holding that criminal liability cannot be fastened merely on allegations of procedural lapses without proof of “gross negligence.” 

The bench of Justice Pankaj Mithal and Justice Prasanna B. Varale emphasized that criminal prosecution of medical professionals requires a significantly higher threshold than civil negligence and cannot proceed on weak or inconsistent evidence. 

The bench allowed the appeal filed by Dr. Supriya Kumari M.C. and set aside the Kerala High Court order that had refused to interfere with proceedings pending before the Judicial Magistrate First Class, Kannur. Consequently, the criminal case pending against the doctor under Section 304-A of the Indian Penal Code for causing death by negligence was quashed and the appellant was discharged from all charges. 

The dispute arose from an incident dating back to May 2002 involving patient K.P. Muralidhar, who had undergone surgery for piles at Dhanalakshmi Hospital in Kannur. The patient underwent surgery on May 29 and was shifted to the post-operative ward thereafter. According to the prosecution, his health deteriorated during the night and he eventually collapsed in the early hours of May 30. Post-mortem examination later revealed an 80% blockage in the left coronary artery, with the cause of death identified as acute coronary insufficiency. 

The prosecution alleged that the appellant, who was serving as a senior anaesthetist, had negligently instructed a nurse to administer “Sensorcaine” rather than personally supervising the process. It was alleged that after the injection was administered, the patient lost consciousness and later died. 

However, the Court found substantial inconsistencies in the evidence relied upon by the prosecution. It noted that the nurse who administered the injection had changed her statements on multiple occasions. Initially, she claimed that the surgeon had instructed her to administer the injection. Later, she changed her version and stated that the anaesthetist had directed her to do so. The Court held that such contradictory statements significantly weakened the prosecution case and reduced the evidentiary value of the allegations against the appellant. 

The Supreme Court further observed that the appellant had already completed her shift at 5 p.m. and had left the hospital after ensuring that the patient was stable. The emergency situation arose later in the evening when other doctors, including an anaesthetist on duty, were physically present in the hospital. Even assuming that the appellant had advised administration of a painkiller over a phone call while at home, such conduct could not amount to criminal negligence. 

The Court also highlighted that the prescribed medicine itself was not disputed. Sensorcaine was acknowledged as the appropriate analgesic in the circumstances, and any adverse consequence arose during the actual administration process. The Court noted that if the injection had been improperly administered into a location other than the epidural space, such an act was beyond the physical control of the off-duty anaesthetist. 

An important factor considered by the Court was the parallel consumer litigation initiated by the deceased’s family. The District Consumer Disputes Redressal Forum had previously examined the issue of negligence and had specifically exonerated the appellant while holding the hospital, surgeon and nurse liable for deficiency of service. Significantly, when the family challenged the compensation amount before the State Commission, it did not challenge the findings exonerating the anaesthetist. 

The Supreme Court relied on its earlier decisions, including Radheyshyam Kejriwal v. State of West Bengal, Videocon Industries Ltd. v. State of Maharashtra, and Prem Raj v. Poonamma Menon, reiterating that where an individual has been exonerated on merits in civil proceedings on identical allegations, continuation of criminal prosecution may amount to abuse of process. 

Reaffirming the principles laid down in the landmark Jacob Mathew v. State of Punjab judgment, the Court emphasized that criminal medical negligence requires proof of conduct that no reasonably competent medical professional would have adopted under similar circumstances. It observed that mere negligence or deficiency in service may attract civil consequences but would not automatically translate into criminal liability. 

The bench also found deficiencies in the expert panel constituted during investigation. It pointed out that the panel did not include an anaesthetist despite the matter directly involving specialised questions relating to epidural anaesthesia and catheter management. The Court held that such an omission weakened the reliability of the expert findings relied upon by the prosecution. 

Further, the Court concluded that the chain of causation necessary for attracting criminal liability under Section 304-A IPC was absent. The medical evidence established that the deceased suffered from an undisclosed and significant coronary blockage and died due to acute coronary insufficiency. According to the Court, attributing such a fatal cardiac event to the conduct of an off-duty anaesthetist stretched the principle of proximate cause beyond permissible legal limits. 

Allowing the appeal, the Court quashed all proceedings against the appellant and discharged her from the criminal case, reaffirming the judiciary’s approach that doctors should not be subjected to criminal prosecution unless there exists clear evidence of gross and reckless conduct amounting to criminal negligence. 

Case Details

Case Title: Supriya Kumari M.C. Versus State Of Kerala & Ors. 

Citation: JURISHOUR-1391-SC-2026

Case No.: Special Leave Petition (Crl.) No. 124 Of 2025

Date: 25/05/2026

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