The National Consumer Disputes Redressal Commission has clarified that performing triple vessel angioplasty in a single session does not constitute medical negligence when the procedure is medically justified, supported by expert opinion, and conducted with informed consent from the patient’s family. This judgment reinforces the principle that adverse outcomes alone cannot establish liability in medical practice.
Background & Facts
The Dispute
Late Chain Roop Arawalia, a 35-year-old male, was admitted to Escorts Heart Centre, Raipur, on 23.10.2006 with acute myocardial infarction and triple vessel coronary artery disease - blockages of 100%, 85%, and 80% in his three major arteries. He underwent angioplasty with stenting of all three vessels on 24.10.2006 by Dr. Satish Suryawanshi, a cardiologist. The patient was discharged on 26.10.2006 at 5:45 pm in stable condition. The next day, on 27.10.2006, he suffered a complete heart block due to a clot in the right coronary artery and died despite emergency intervention.
Key Facts
- The patient had suffered a myocardial infarction three days prior to admission (20.10.2006)
- Left ventricular ejection fraction was 30 - 35%, indicating severe heart dysfunction
- The treating cardiologist, Dr. Satish Suryawanshi, held M.B.B.S., M.D. Medicine, and D.M. Cardiology qualifications
- He had 4.5 years of experience in interventional cardiology, including independent cath lab work since January 2006
- The patient’s father, Jai Chand Arawalia, and treating physicians Dr. Deshpande (Raipur) and Dr. Tiwari (Mumbai) were consulted regarding treatment options
- CABG was discussed as an alternative but rejected by the family due to high risk associated with low ejection fraction
- Informed consent for angioplasty and stenting was signed by the patient’s brother, Pramod Kumar Arawalia, on 23.10.2006
- The procedure used Endeavor drug-eluting stents, known for low thrombosis risk
- Discharge occurred after 48 hours, consistent with standard protocol
Procedural History
- 20.10.2006: Patient suffers myocardial infarction
- 23.10.2006: Consultations with Dr. Deshpande and Dr. Tiwari; informed consent signed
- 24.10.2006: Triple vessel angioplasty and stenting performed
- 26.10.2006: Patient discharged at 5:45 pm in stable condition
- 27.10.2006: Patient re-admitted with complete heart block; died same day
- 13.11.2006: Criminal complaint lodged at Moudhapara Police Station, Raipur
- 25.06.2007: Consumer complaint filed before State Consumer Disputes Redressal Commission, Chhattisgarh (CC No. 5/2007)
- 25.01.2012: State Commission dismissed complaint, holding no medical negligence
- 11.02.2012: First Appeal No. 119/2012 filed before National Consumer Disputes Redressal Commission
- 05.06.2026: Arguments concluded before NCDRC
- 01.07.2026: Judgment pronounced dismissing the appeal
The Parties' Positions
Appellants (Family of Deceased):
- Alleged that triple vessel stenting in one sitting was medically inappropriate
- Claimed Dr. Suryawanshi lacked experience to perform such a complex procedure
- Contended discharge after 48 hours was premature
- Argued that CABG should have been performed instead
- Asserted that consent was not truly informed and that the doctor concealed his lack of expertise
- Relied on AIIMS report stating discharge could have been delayed and triple vessel stenting was "not recommended" without hemodynamic compromise
Respondents (Hospital and Doctor):
- Maintained that triple vessel stenting was medically appropriate and supported by literature
- Demonstrated that CABG was offered but rejected by the family due to high risk
- Showed that Dr. Suryawanshi was qualified and experienced
- Provided AIIMS clarification that stenting was justifiable given the patient’s history
- Argued that discharge at 48 hours was standard and the subsequent cardiac event was unrelated to the procedure
- Cited medical literature from American Heart Journal, JACC, and others supporting multi-vessel stenting
- Emphasized that no expert contradicted the procedure’s safety
Relief Sought
The appellants sought:
- Compensation of Rs. 50,00,000 for loss of life
- Rs. 10,00,000 for mental agony and suffering
- Rs. 5,00,000 for medical expenses
- Costs of litigation
- A direction to the Medical Council to take action against Dr. Suryawanshi
The Legal Issue
The central question was whether performing triple vessel angioplasty in a single session, followed by discharge within 48 hours, constitutes medical negligence under the Consumer Protection Act, 1986, when the procedure is medically justified, supported by expert opinion, and performed with informed consent.
Arguments Presented
For the Appellant
The appellants relied on the AIIMS expert report, which stated that triple vessel stenting in one sitting is "not recommended" in the absence of hemodynamic compromise and that discharge after 48 hours "could have been delayed." They argued that Dr. Suryawanshi’s answers to 54 interrogatories revealed evasiveness regarding his experience, particularly in performing three-vessel stenting. They invoked the Bolam Test from Jacob Mathew v. State of Punjab (2005) and contended that the doctor’s conduct was unreasonable given the patient’s low ejection fraction. They further argued that the absence of affidavits from Dr. Deshpande and Dr. Tiwari invalidated the respondents’ claim of collaborative decision-making.
For the Respondent
The respondents countered that AIIMS had clarified its opinion, stating that triple vessel stenting was justifiable if the patient’s history was accurate - which it was. They submitted that the patient’s family, after consulting two cardiologists, voluntarily chose angioplasty over CABG due to the high mortality risk of surgery in patients with ejection fraction below 35%. They cited authoritative medical literature from the Journal of the American College of Cardiology, Heart, and Circulation supporting multi-vessel stenting as safe and equivalent to CABG in selected cases. They emphasized that the procedure was successful, the patient was discharged in stable condition, and the fatal event occurred 48 hours later due to a new thrombotic event unrelated to the stenting.
The Court's Analysis
The NCDRC undertook a meticulous review of the medical evidence, expert opinions, and procedural history. It noted that the AIIMS report, while initially cautioning against triple vessel stenting in the absence of hemodynamic compromise, later clarified that given the patient’s history of recent myocardial infarction and low ejection fraction, the procedure was justifiable. The Court emphasized that expert opinions must be read in their entirety and that clarifications provided in response to queries are part of the evidentiary record.
"The clarification issued by AIIMS has not been successfully controverted by any other expert evidence or material or even medical literature so as to contradict the same."
The Court found no evidence that Dr. Suryawanshi lacked the requisite skill. His qualifications, experience, and prior independent practice in cath labs were documented. The Court rejected the argument that the doctor’s experience was concealed, noting that the family had consulted multiple cardiologists before consenting to the procedure.
The Court also examined the informed consent form signed by the patient’s brother on 23.10.2006, which explicitly authorized both angiography and angioplasty. The Court held that the consent was not obtained under duress, as the family had actively consulted external specialists and weighed alternatives.
"The procedure which was carried out, was through an established protocol and there is no material to indicate that the Angioplasty was done without following the due procedure as prescribed."
The Court distinguished between an adverse outcome and negligence. It relied on M.A. Biviji v. Sunita & Ors. (2024) and Neeraj Sud v. Jaswinder Singh (2024), holding that a doctor cannot be held liable merely because a patient’s condition deteriorated after a procedure that was medically sound and properly performed.
The Court further noted that the family had not produced any expert testimony contradicting the respondents’ position. The absence of affidavits from Dr. Deshpande and Dr. Tiwari weakened the appellants’ case. The State Commission’s findings, supported by voluminous medical literature and expert clarification, were found to be well-reasoned and evidence-based.
The Verdict
The appeal was dismissed. The National Consumer Disputes Redressal Commission upheld the State Commission’s order dated 25.01.2012, holding that there was no medical negligence. The Court found that the triple vessel angioplasty was performed in accordance with accepted medical standards, with informed consent, and supported by expert opinion. The death was attributed to a new thrombotic event occurring 48 hours post-discharge, unrelated to the procedure. No compensation, costs, or directions were granted to the appellants.
What This Means For Similar Cases
Medical Judgment Cannot Be Second-Guessed After Adverse Outcome
- Practitioners must document all treatment options discussed with the patient’s family
- A negative outcome alone does not establish negligence; the focus must be on whether the standard of care was met
- Courts will not substitute their judgment for that of qualified medical professionals absent clear evidence of deviation from accepted practice
Informed Consent Must Be Demonstrated, Not Assumed
- Consent forms signed by family members, especially after consultation with external specialists, carry significant weight
- If a patient’s family consults multiple doctors before consenting, the defense of informed consent is strengthened
- Avoid relying solely on verbal consent; written documentation is critical
Expert Opinions Require Full Context
- Partial excerpts of expert reports are insufficient; clarifications and follow-up responses must be considered
- When AIIMS or other reputed institutions provide nuanced opinions, courts will weigh the entire exchange, not just initial conclusions
- Parties must submit counter-expert reports if challenging authoritative opinions
Multi-Vessel Angioplasty Is Legally Recognized
- Performing stenting on multiple vessels in one session is not per se negligent
- Medical literature supporting the procedure must be cited and preserved
- The choice between CABG and angioplasty is a clinical decision, not a legal one, provided the patient is adequately informed
The Bolam Test Remains Central
- A doctor is not negligent if their conduct is supported by a responsible body of medical opinion
- The burden shifts to the complainant to prove unreasonableness, not just difference of opinion
- Defensive medicine is discouraged; doctors must be allowed to exercise clinical judgment without fear of litigation for unforeseen complications
