Jacob Matthew vs State of Punjab
AIR 2005 SC 3180
Case Summary
[Criminal Negligence]
Facts
Jacob Mathew, a senior doctor, was charged with criminal negligence leading to the death of a patient in a hospital in Punjab. The case revolved around the allegation that the oxygen cylinder in the hospital was empty, leading to the patient’s death. The issue was whether the doctor’s actions amounted to criminal negligence under Section 304A of the Indian Penal Code.
Issue
1. Does medical negligence amount to a criminal act under Section 304A of the Indian Penal Code?
2. What is the standard of care expected from medical professionals in such cases?
Rule
To constitute criminal negligence, a higher degree of negligence is required than for civil liability. A medical professional would only be held liable if they had grossly failed to meet the standard of care and skill expected of a reasonably competent professional.
Judgement
The Supreme Court held that there was no criminal negligence in this case because the doctor followed acceptable medical practices. A doctor is expected to use a reasonable amount of care and skill, but liability arises only if gross negligence is established.
The court acquitted Jacob Mathew, concluding that criminal liability could not be imposed on him as the requisite standard of gross negligence was not met. The court emphasized that doctors cannot be penalized for honest mistakes or a mere error in judgment
Anushka Shekhawat
Manipal University, Jaipur
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