By Diksha Sharma-
Being an Indian citizen constitution has guaranteed us many fundamental rights to protect public interest. It is just a limitation to the powers of the state and preventing them to intrude the liberty of citizens. Every citizen of country irrespective of their caste, religion, color or sex has these fundamental rights.
The significance of fundamental rights is that it helps in the betterment of people in a society. For example, the right to equality prohibits discrimination based on color, caste, gender, etc. These rights are justifiable and hence, if one’s right are breached than he can go to the court for seeking remedy.
Article 21 of the constitution provides “No person shall be deprived of his life and personal liberty except according to procedure established by law”. This right is held to be the heart of the constitution. Constitutional Bench of the Supreme Court in Kehar Singh v. Union of India AIR 1989 SC 653, held that
“To any civilized society, there can be no attributes more important than the life and personal liberty of its members. These twin attributes enjoy a fundamental ascendancy over all other attributes of the political and social order.”
We all have heard a word “negligence” which simply means carelessness. This carelessness can be sometimes so dangerous that can harm a person or even can cause death of a person. In the cases of negligence life of a person is at a risk by other person. This basically breaches the fundamental right to life by the way of mere negligence or carelessness.
How negligence violate this right? How mere negligence can result into a death of a person? What are constitutional remedies provided against the act of negligence? We are going to study the concept of “negligence” and will come across with the answers to these questions.
Essence of Negligence
The word “Negligence” indicates lack of care which was derived from a Latin word “Negligentia” which means failing to pick up. Commonly saying, when an individual acts carelessly and injured another person than he will be legally liable for the harm under the valid rule of “Negligence”. Negligence can be both civil wrong and criminal wrong.
Negligence is a tort, which is a civil wrong. According to the Law of Torts “It is a civil tort which occurs when a person breaches his duty of care which he owed to another due to which that other person suffers some hard or undergoes some legal injury”.
Negligence has two meanings in law of tort:
- Negligence as state of mind- Negligence as a mode of committing certain torts e.g. negligently or carelessly committing trespass, nuisance or defamation. In this context it denotes the mental element.
- Negligence is considered as a separate tort- It means a conduct which involves the risk of causing damage, rather than a state of mind. The House of Lords in the case of Donoghue v. Stevenson(1932) A.C. 562 “treats negligence, where there is duty to take care, as specific tort in itself and not simply as an element is some more complex relationship or in some specialized breach of duty”.
Negligence is, accordingly, a mode in which many kinds of harms may be caused, by not taking such adequate precautions as should have been taken in the circumstances to avoid or prevent that harm, as contrasted with causing such harm intentionally or deliberately.
Essentials of Negligence
In an action of negligence, plaintiff has to prove following essentials:
Duty of care to the plaintiff
It means a legal duty rather than a mere moral, religious or social duty. The Plaintiff has to establish that the defendant owed to him a specific legal duty to take care, of which he has made a breach. Such as there is no general rule to define such duty.
In Donoghue v. Stevenson (1932) AC 562, the appellant plaintiff drank a bottle of ginger beer which was brought from a retailor by her friend. The bottle which was of dark opaque glass in fact contained the decomposed body of snail.
The House of Lords held that the manufacturer owed her a duty to take care that the bottle did not contain any noxious matter and that he would liable for the breach of duty.
According to Lord Atkins:
“A manufacturer of the products, which he sells in such a form as to show that he intends them to reach the ultimate consumer in the form in which they left him with no reasonable possibility of intermediate examination and with the knowledge that the absence of the reasonable care in the preparation or putting up of the products will result in an injury to consumers’ life or property, owes a duty to the customer to take that reasonable care.”
The House of Lords also rejected the plea that there was no contractual relationship between the manufacturer and plaintiff.
Breach of Duty
Breach of Duty means non- observance of due care which is required in a particular situation. What is the standard of care required? The standard is that of a reasonable man or of a reasonably prudent man.
It is also necessary that the defendant’s breach of duty must cause damage to the plaintiff. The plaintiff has also to show that the damages thus caused are not too remote a consequence of defendant’s negligence.
Proof of Negligence (Res Ipsa Loquitur), as a general rule it is for the plaintiff to prove that the defendant was negligent. The initial burden of making out at least prima facie case of negligence as against the defendant lies heavily on the plaintiff but once this onus is discharged it will be for the defendant to prove that the incident was the result of negligence. According to the Latin maxim ‘res ipsa loquitur’ which means the thing speaks for itself. In such a case it is sufficient for the plaintiff to prove accident and nothing more. The defendant can, however, avoid his liability by disapproving negligence on his part.
When Does Negligence Become Criminal Wrong?
Negligence is when carelessness results in an injury to a person or property. But what happens when a person’s actions aren’t merely careless, but reckless? There is such a thing as criminal negligence.
If I have a word for criminal negligence the primary element that come up to mind is “Crime”.
We all in our daily life usually hear this word in numerous senses. YES, a crime is an immoral activity or an unlawful act done by an individual or a group of individual which is against a person, a society or even state also. It is an illegal action which can be harmful and dangerous sometimes. There is a popular word for those who commits crime i.e. Criminal. A person by whom any illegal act or offence has been committed is criminal.
It is quite understood that a crime is an intentional cause but sometimes crime involve reckless or negligent conduct rather than purposeful grounds.
To understand this let’s take an example to explain: assume a man is drinking and driving on a street, and suddenly he kills someone on the road, he will be held criminally negligent. The reason is both killing and drink and driving are crime, hence he will be charged for murder and held criminally liable.
The example clearly shows us that an individual is intentionally neglecting the laws of the government by drinking and driving. Generally speaking, it is the amount of damages incurred which is determinative of the extent of the liability in tort, but in criminal law it is not amount of damages but the amount and degree of the negligence that is determinative of the liability. Criminal Negligence is what when a person ignores an obvious risk of life and safety of other person.
It must include two important points i.e. knowledge of a danger and it should be more than a mistake or must be an unforgivable act. To fasten the liability in criminal law, the degree of negligence has to be higher than that of the negligence enough to fasten liability for damages in civil law.
To prove that accused has acted with criminal negligence prosecutor must have to prove these important following ingredients:-
- If a person has acted recklessly and generated a high risk of death or bodily injury,
- A person would have known that these acts would create such a risk. 
In order to hold the existence of criminal rashness or criminal negligence it shall have to found out that the rashness was of such a degree as to amount of taking a hazard knowing that the hazard was of such a degree that injury was most likely imminent.
The element of criminality is introduced by the accused having run the risk of doing such an act with recklessness and indifference’s to be consequences.
Lord Atkins in his speech in Andrews v. Director of Public Prosecutions, (1973) A.C. 576 stated, “Simple lack of care- such as will constitute civil liability is not enough; for purposes of the criminal law there are degrees of negligence; and a very high degree of negligence is required to be proved before the felony is established”. Thus a clear distinction exists between “simple lack of care” incurring civil liability and “very high degree of negligence” which is required in criminal cases.
As today, we all are aware of the situation our country and its people going through. A dangerous and harmful virus; Covid-19, which is effecting us very rapidly. This virus has taught us preciousness of life, personal growth and importance of health etc. On one hand we all have leaned many lessons and on other hand it has also made us think about medication system of our country.
There are many reports of patients being denied of medical assistance. Human body and medical science – both are too complex to be easily understood. The carelessness by our doctors and their malpractices has lead to increment in the cases of the virus. This is just an undeviating sign towards the Medical Negligence.
Lord Peter said in his speech in the same case “A high degree of negligence has always been demanded in order to establish a criminal offence than is sufficient to create civil liability”.
Law laid down by Straight, J. in the case Reg v. Idu Beg (1881) 3 All. 776, has been held good in cases and noticed in Balchandra woman Pathe v. State of Maharashtra 1968 Mh.L.J. 423, a three –judge bench decision of this court.
It has been held that while negligence is an omission to do something which a reasonable man, guided upon those considerations which ordinarily regulate the conduct o human affairs, would do, or doing something which a prudent and reasonable man would not do; criminal negligence is the gross and culpable neglect or failure to exercise that reasonable and proper care and precaution to guard against injury either to the general public or to an individual in particular, which having regard to all the circumstances and of which the charge has arisen, it is the imperative duty of the accused person to have adopted.
During this pandemic not our doctors alone responsible for this but our government is also have hands in glove with them. Government is not taking any strict action regarding this but they are making their own advantages. They are just ignoring this pandemic or they are getting relaxed from this pandemic by doing nothing. Doctors alone cannot handle the situation but government also has to join hands with them to fight with the situation.
Few days back, former Madhya Pradesh chief minister Kamal Nath accused the BJP government in the state of failing to manage the COVID-19 crisis and termed it as “criminal negligence” on the part of the administration. Nath argued that hospitals have no beds, injections and oxygen and many more.
He also claimed that the actual number of COVID-19 deaths in the state was being hidden and that the figures were much higher than the official statistics. Everyone is blaming each other but no one is thinking about the people who are suffering and dying.
Congress accused the ruling party for Criminal Negligence in dealing with the second wave of covid-19. The party called it “shameful” as PM Narendra Modi was busy in poll rallies in West Bengal instead of being “at his desk” to deal with the biggest health emergency to strike the country.
Actus Non-Facit Reum Nisi Mens Sit Rea
Mostly crimes are done with some unlawful intention or with any evil thought. There is a famous maxim “Actus Non-Facit Reum Nisi Mens Sit Rea”. This maxim means that guilty intention and guilty act both constitutes the crime. This maxim is divided into further two elements: a) Mens rea (guilty mind); b) Actus reus ( guilty act ).
If I say that a mother intentionally dose not feed his baby leading to death of a child. Is this a crime? Are Mens Rea and Actus Reus present? Should mother held guilty? The answer is definitely YES because she was having cleared intentions to kill her baby. Mens Rea is present as of guilty mind and Actus Reus is also there as guilty act was done by not feeding the baby.
If I talk about negligence is it necessary to have a guilty mind or any unlawful intention? Or is it necessary to do a guilty act for negligence? The answer is probably YES. However in some situations we see that some circumstances are there in which guilty mind is not present except guilty act and that guilty act lead to criminal negligence. For more clarifications to this point let us understand the concepts of Mens Rea and Actus Reus.
Mens Rea (Guilty Mind) an act becomes a crime when it is done with Evil Intentions or to cause some injury to another person. Guilty mind is very essential to commit a crime or any criminal activity otherwise the person will not be held liable for any criminal offence. No person can be held liable for an Act done under any fear or force.
This means that people doing any crime are having full knowledge that what they are doing and why they are doing and they are fully aware of the results. It has allowed the criminal justice system to differentiate between someone who did not mean to commit a crime and someone who intentionally set out to commit a crime.
The term mens rea comes from the writings of Edward Coke, an English jurist who wrote about common law practices. He advocated that “an act does not make a person guilty unless mind is also guilty”.
In Jacob Mathew v. State of Punjab AIR 2005 SC 3180, held by Supreme Court that the essential ingredient of Mens Rea should be considered when the charge in a criminal court consists of criminal negligence. Breach of duty of care becomes criminal in nature when there exists sufficient Mens Rea in act of negligence.
Actus Reus (Guilty Act) is a term used to describe any criminal act. Actus reus is commonly defined as a criminal act that was the result of voluntary bodily movement. This describes a physical activity that harms another person or damages property. Anything from a physical assault or murder to the destruction of public property would qualify as an actus reus.
To prove any crime Actus Reus is very important because only having guilty mind does not mean that crime has been committed unless and otherwise that state of mind changes into physical state to commit crime. Actus Reus generally comprises of three basic components: a voluntary act or failure to perform an act (omission), causation, a social harm condemned under a criminal statute.
Actus Reus and Criminal Negligence
Omission, as an act of criminal negligence, is another form of Actus reus. Since, it involves taking no action that would have prevented injury to another person. An omission could be a situation by you that can created a dangerous state of affairs just like not feeding an infant who has been left in your care, or any carelessness by not completing a work properly which resulted in an accident.
In all of these cases, the doer’s failure to complete a necessary activity caused harm to others or in simple words we can say that the person responsible for the injury is liable for the guilty act although he was not having any guilty mind.
Suppose, an individual who operates a car or other vehicle while under the influence of alcohol or drugs and injures another person, as a result. Although a person was not having any intention to cause injury to that individual but his act of driving while he was badly drunk lead to it.
What do I accept as true is that guilt and innocence of a person both the phases are dependent on one’s mind that how a crime is committed by a person whether intentionally or not. Sometimes an act which is done without intention can also lead to a crime.
Medical and Professional Negligence
Profession is an occupation which posses special skills, learning and knowledge. It is an activity in which an individual is expertise in particular area. It is basically done to serve the society with one’s special knowledge and skills. A person who has qualified degrees, knowledge in particular field and practices the profession is “Professional”.
Like our lawyers, Doctors, Charted Accountants and Teachers etc they all have some special teachings and education. They all have some professional standards which are to be followed up: honesty, integrity, loyalty and accountability and many more.
Any reasonable man entering into a profession which requires a particular level of learning to be called as professional of that branch, impliedly assures the person dealing with him that the skill which he professes to possess shall be exercised and exercised with reasonable degree of care and caution. He does not assure his client of the result.
Just as, lawyer will not tell his client that the client will win the case in all circumstances. A physician would not assure the patient of full recovery in each case. The only assurance with such a professional can give or can be understood to have given by implication is that he is possessed of the requisite skills in that branch of profession which he is practicing and while undertaking the performance of the task entrusted to him he would be exercising his skills with reasonable competence. This is all the person approaching the professional can expect.
Negligence by Professionals
In the law of negligence, professionals such as lawyers, doctors, architects and other are included in the category of person professing some special skills or skilled persons generally.
The concept of negligence stays the same in professional negligence. When these ethical standards get violated and there is a breach of duty to serve the society, then Professional Negligence takes place.
Judged by the above standards a professional may held liable for negligence on one of the two findings: either he was not possessed of the requisite skills which he professed to have possessed, or, he did not exercise, with reasonable competence in the given case, the skill which he did possess.
However, it is not necessary for every professional to possess the highest level of expertise in that branch which he practices.
In Michael Hyde and Associate v. J.D. Williams and Co. Ltd. (2001) P.N.L.R. 233. CA, Sedley L.J. said that where a profession embraces a range of views as to what is an acceptable standard of conduct, the competence of the defendant is to be judged by the lowest standard that would be regarded as acceptable.
In the opinion of Lord Denning, as expressed in Hucks v. Cole (1968) 118 New L.J. 469, a medical practitioner will not be held liable simple because things went wrong from mischance or misadventure or through an error of judgment in choosing one reasonable course of treatment in preference of another. A medical practitioner would be liable only where his conduct fell below that of the standards of a reasonable competent practitioner in his field.
It is not enough for the defendant to show that standard of care and the skill attained want that of the ordinary competent medical practitioner exercising an ordinary degree of professional skills. No sensible professional would intentionally commit an act or omission which would result into loss or injury to his client as the professional reputation is at the stake. A single failure may cost his whole career.
The rule of the Res Ispa Lequitur may is not of universal application and has to be applied with extreme care and caution to the cases of professional negligence and in particular to that of the medical negligence.
The rule of the Res Ispa Lequitur is a rule of evidence which in reality belongs to law of Torts.
According to the law of Torts the event itself is indicative of negligence. A medical practitioner faced with an emergency ordinarily tries his best to redeem the patient out of his sufferings. He does not gain anything by acting with negligence or by omitting to do an act.
Therefore, it will be of the complainant to clearly make out a case of negligence before a medical practitioner is charged with or proceeded against criminally.
Mistakes or Negligence in the health profession may result into minor injuries or even lead to some serious injuries and these mistakes could even lead to death. Dealing with the cases of medical professionals requires deep understandings of the practical side of the medicine.
The deep reason behind medical negligence is that the carelessness of the doctors are often find out in various cases like during the diagnosis, during operations, while injecting anesthesia, etc.
For instance, a doctor leaving any unknown article in the body of the patient such as a sponge or bandage, etc. after the surgery and patient have to suffer with a lot of pain.
This is a serious negligence as it can harm the patient and can cause severe damages.
A doctor owes certain duties of care to his patients, they are as follows:
- It is his duty to decide whether he wants to undertake the case or not,
- It is his duty to decide what treatment to give and;
- It is his duty to decide the administration of treatment.
In Jasbir Kaur v. State of Punjab 1995 ACJ 1048, a newly born child was found missing from the bed in a hospital. The child was found bleeding and near the wash-basin of the bathroom. The hospital authorities argued that the child had been taken away by a cat which caused the damage to him. The court held that the hospital authorities were negligent and had not taken due care and precaution. Thus, awarded with the compensation of amounting Rs. 1 lakh.
The standard of care needed in a particular case dependents on the professional skill expected from persons belonging to a particular class.
A surgeon or anesthetist will be judged by the standard of an average practitioner of class to which he belongs or holds himself out to belong. In case of specialists, a higher degree of skill is needed.
Explaining the nature of duty of care in medical profession, the Supreme court observed in Dr. Lakshman Balkrishna Joshi v. Trimbak Bapu Godbole(A.I.R. 1989): “The petitioner must bring to his task a reasonable degree of skill and knowledge and must exercise a reasonable degree of care. Neither the very highest nor a very low degree of care and competence judged in the light of the particular circumstances of each case is what the law requires. The doctor, no doubt, has discretion in choosing treatment which he proposes to give to the patient and such discretion is relatively ampler in cases of emergency.”
If the doctor is not attending the patient with proper care moreover by not deciding how to treat the patient’s disease or not even attentive for the case and due to this carelessness patent dies or have to suffer a lot of pain and harm than the doctor is liable for Criminal Negligence.
Today, Medical negligence cases are on the rise partly due to the rapidly proliferating number of healthcare providers with inadequate infrastructure, and partly owing to the inadequate skills and outdated knowledge of healthcare professionals.
It was held in the case of Sishir Rajan Saha v. The state of Tripura A.I.R. 2002 Gauhati 102, that if a doctor did not pay enough attention to the patients in government hospitals as a result of which the patient suffers, the doctor can be held liable to pay compensation to the patient.
The criminal law has invariably placed the medical practitioner on a pedestal different from ordinary mortals. However, if the elements like the motive or intention, the magnitude of the offense and the character of the accused are established then it makes him liable under the criminal law.
Res ipsa loquitur, in terms of medical malpractice, it refers to the cases where the doctor’s treatment was faraway from the set standards of care under that negligence is assumed. It means that by applying the principle the judge has accepted that the negligence has occurred.
The Supreme Court in Jacob Mathew v. State of Punjab A.I.R. 2005 S.C. 3180, explained: a professional entering into certain profession is deemed to have knowledge regarding that profession and it is assured impliedly by him that a reasonable amount of care shall be taken to profess his profession. The person can be held liable under negligence if he did not possess the required skills to profess or he failed to take essential amount of care to profess the said profession.
Further the Supreme Court also held that “accident during the course of medical or surgical treatment has a wider meaning. Ordinarily, an accident means an unintended and unforeseen injurious occurrence; something that does not occur in the usual course of events or that could be reasonably anticipated. Care has to be taken to see that the result of an accident which is exculpatory may not persuade the mind to confuse to with consequences of negligence”.
From the above case it is cleared that a simple lack of care or an accident is not proof of negligence on the part of medical professionals. A professional can only held liable for negligence either he was not having requisite skills or he did not exercised with reasonable competence.
Today, Medical negligence cases are on the rise partly due to the rapidly proliferating number of healthcare providers with inadequate infrastructure, and partly owing to the inadequate skills and outdated knowledge of healthcare professionals.
People are suffering a lot due to this pandemic some are losing their lives and some are losing their loved ones. This pandemic has destroyed many lives and no end has seen till now. Many are fighting battle against this from a child to the old one. Whole country is praying for safety and good health of every one to fight against the virus.
Many doctors and medical practitioners are considered as “worriers” as they are also fighting against the battle more than us. They are working day and night without any interval to serve us with good treatment and to save our lives. But on the other side these are also coming up as an institution of mismanagement of covid-19. Covid- 19 has increased the cases of medical negligence recently.
The sub-inspector from Uttar Pradesh whose wife was tested positive for COVID-19 and was admitted to the government hospital on April 20,2021, after she complained of breathing problems. She breathed her last at the facility on April 22. The cop revealed that his wife died due to medical negligence.
The cop was identified as Bhik Chand. The cop alleged that medicines were not provided to his wife. He added that he approached the medical superintendent at least 50 times but to no avail, The Times of India reported.
He said, “She was not even given water and eventually died.” Chand said, “My wife was killed by the hospital. They did not administer any treatment to my wife. I had complained to the SP (city) who then sent an inspector but we did not get any assistance from the hospital. I will get an FIR registered and take this case to its logical conclusion. “
In Aligarh on 3 may 20121, The body of a COVID-19 patient kept lying on a bed at a government hospital here for more than 14 hours after he died, his family alleged, adding that he was subjected to wrong treatment. After a complaint in the matter against Deendayal Upadhyay Hospital to the district authorities, Sub-Divisional Magistrate Kol Ranjit Singh on Sunday ordered a probe. He said those found guilty would be duly punished. According to the complaint, Brajesh Sharma (69) died on Friday night and his family was “kept in the dark” about the incident.
He was admitted at the hospital on Thursday and was treated on the basis of the medical tests of the previous occupant of the bed—Hariom Sharma, the complaint said. Brajesh’s family was unable to find him as the hospital didn’t have an entry with his name, it said, adding the error was detected by the time his treatment started in the previous patient’s name.
Criminal Negligence Under India Penal Code
The act of negligence can be civil wrong as well as criminal wrong. As we have discussed that in civil law or Tort if the act of defendant cause injury to plaintiff by the act if negligence than he has to compensate plaintiff.
In Criminal Law if any injury is there than the defendant will be charged and will punished too. Indian Penal Code has covered the negligence under various provisions.
- Section 269 punishes a person whose acts is negligent and is likely to spread infection of disease dangerous to life. Therefore, this provision considers that negligence of any person in affecting the public health is culpable.
- Section 286 holds a person criminally liable in cases where the person owing to his negligent conduct has caused danger to the human life and is likely to injure another person. The negligent conduct under this provision should be for explosive substance. This provision covers both action and omission in conducting negligently.
- Sections 336, 337 and 338- These provisions consider three consequences of negligence as offences-
- Endangering the life or personal safety of others (Section 336)
- Causing hurt (Section 337)
- Causing grievous hurt (Section 338)
But what happens if this criminal negligence results into the death of the plaintiff?
Casing Death by Negligence
According to Section 304-A of the Indian Penal Code, 1860, “if a person commits a rash or negligent act which amounts to culpable homicide then the person will be punished with imprisonment for a term which may extend to two years or with fine or both”.
In Kurban Hussein Mohomedalli Rangawalla v. State of Maharashtra (1965) 2 SCR 622, while dealing with the Section 304-A of the IPC, the following statement of Sir Lawerence Jenkins in Emperor v. Omkar Rampratap 4 Bom. L.R. 679, was cited with approval:-
“To impose Criminal Liability under section304-A, Indian Penal Code, it is necessary that the death should have been the direct result of rash and negligent act of the accused, and that act must be the proximate and efficient cause without the intervention of another’s negligence. It must be the causa causans; it is not enough that it may have been the causa sine qua non”.
In Dr. Suresh Gupta v. Govt. of N.C.T. of Delhi and Anr. AIR 2004 SC 4091, the court quashed the proceedings for medical negligence for fixing criminal liability on a doctor or surgeon, the standard of negligence required to be proved to be as high as can be described as “gross negligence” or recklessness. The doctor did not take reasonable care due to which the patient died.
As per medical opinion produced by prosecution cause of death is because of not introducing a cuffed endotracheal tube of proper size as to prevent aspiration of blood from the wound in respiratory passage. This act attributed to a doctor, even if accepted as true, can be described as negligent act as there was lack of due care and precaution, for which he may be liable in tort. The court held that the said act cannot be described as so grossly negligent or reckless as to make him criminally liable under section 340A of IPC.
On the concluded part thanks to the drafters of the constitution and laws to protect rights of the citizens against the civil and criminal wrongs that not only affect the victim but to those people also who are connected with him.
Life of a person is very precious as no one can understand the pain of the family members whose loved once has gone forever just by a single act of carelessness done by us. Every person has a right to life and no one can take it from anyone.
There are rights and strict rules to follow them but besides these rules, “Humanity” is one of the major and the basic rule of life which everyone is supposed to follow not just for our dear once but for another person even he is stranger to you.
Before all these laws and rules our Indian Ethics and Beliefs come up which do not allow killing a person whether intentionally or not.
A person should not do any act which can become a curse for whole life of another person because your single act of carelessness can change the entire life of a victim. Our judicial system is there to punish such type of acts but they cannot cover up the pain and grief of the sufferer and his family.
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