The new Code and the Criminal Liability of Doctors, no need to get panic : Adv. ROHiT ERANDE ©

 

The new Code and the Criminal Liability of Doctors :

Adv. ROHiT ERANDE. ©

It will not be an overstatement to say that, these days the Doctors are doing Defensive practice. There are umpteen number of incidences wherein if a patient dies, then the Doctors may face Civil Action for damages i.e. cases in a consumer court and/or Criminal Action, wherein the Doctors may get arrested on the alleged ground of Medical Negligence  and previously  charges under Section 304-II instead of Sec.304-A of IPC used to be imposed.

However, now the Bharatiya Nyaya Sanhita Act, 2023 (BNS) received approval from the Hon’ble President and it came into effect since 1st July 2024 and the new Code has brought many changes and as far as Doctors is concerned, we will try to compare these changes.



Whether under old regime or the new one, it is the prerogative of Police Authorities to put the  sections in the FIR, but ultimately  it's legality is decided by the Courts.

Lets' see in nutshell ;

304. Punishment for culpable homicide not amounting to murder— Whoever commits culpable homicide not amounting to murder shall be punished with 1[imprisonment for life], or imprisonment of either description for a term which may extend to ten years, and shall also be liable to fine, if the act by which the death is caused is done with the intention of causing death, or of causing such bodily injury as is likely to cause death, or with imprisonment of either description for a term which may extend to ten years, or with fine, or with both, if the act is done with the knowledge that it is likely to cause death, but without any intention to cause death, or to cause such bodily injury as is likely to cause death.

There is a famous adage which says, "Every murder is culpable homicide, but every culpable homicide is not a murder". The Medical Negligence cases fall under the later part. 

This section is now replaced by Sec.105 of BNS as under :

It provides for statutory minimum of 5 years as there was no minimum punishments earlier under IPC in this case.

 Section 105 :  Whoever commits culpable homicide not amounting to murder, shall be punished with imprisonment for life, or imprisonment of either description for a term which shall not be less than five years but which may extend to ten years, and shall also be liable to fine, if the act by which the death is caused is done with the intention of causing death, or of causing such bodily injury as is likely to cause death; or with imprisonment of either description for a term which may extend to ten years and with fine, if the act is done with the knowledge that it is likely to cause death, but without any intention to cause death, or to cause such injury as is likely to cause death.

So if this Section is imposed like earlier 304 of IPC, then it becomes a non-Bailable offense and punishment is 10 years.!! The job of the Police Authorities is very important in such cases as to which sections are to be imposed. If Sec.304 is imposed, then Doctors have to go for anticipatory bail for avoiding arrest.

The Doctor community is talking about new Sec.106 of BNS which is similar to the earlier provision of Sec.304A.

304A. Causing death by negligence.—Whoever causes the death of any person by doing any rash or negligent act not amounting to culpable homicide, shall be punished with imprisonment of either description for a term which may extend to two years, or with fine, or with both. 

Now let’s see Sec.106 -

106. (1) Whoever causes death of any person by doing any rash or negligent act not amounting to culpable homicide, shall be punished with imprisonment of either description and shall also State Medical Register under that Act for a term which may extend to five years, and shall also be liable to fine; and if such act is done by a registered medical practitioner while performing medical procedure, he shall be punished with imprisonment of either description for a term which may extend to two years, be liable to fine.

• Explanation.— For the purposes of this sub-section, “registered medical practitioner” means a medical practitioner who possesses any medical qualification recognized under the National Medical Commission Act, 2019 and whose name has been entered in the National Medical Register or a State Medical Register under that Act.

(2) Whoever causes death of any person by rash and negligent driving of vehicle not amounting to culpable homicide, and escapes without reporting it to a police officer or a Magistrate soon after the incident, shall be punished with imprisonment of either description of a term which may extend to ten years, and shall also be liable to fine.

For the 1st time, the Doctors or that matter perhaps any such profession has been directly mentioned in the section and this section would be applicable to all the registered Doctors whether they are Allopaths or not. (only quacks are not included !)

Further this section would come into play only when some mishap happens while performing medical procedure and not otherwise.

In a way it is good that the punishment has been fixed for Doctors. Previously the Fine was optional, but in the current situation the Fine is mandatory, even if no punishment is saddled upon.

Nevertheless, the Judicial Principles in case of Arrest of Doctors would remain the same !

Be that so, but the Principles laid down by Hon’ble Supreme Court in case of  case of arrest of Doctors in Medical Negligence Cases, would be applicable even after implementation of new Code

The Hon. Supreme Court in its 5 judges constitutional Bench judgment, in the celebrated case of Lalita Kumari V/s. state of U.P. (2014 (2) SCC 1) - ( https://indiankanoon.org/doc/10239019/) has given solace to Doctors in the matters of arrest. The bench was dealing with mandatory lodging of FIR in cognizable offenses, it was observed, 

"Although, we, in unequivocal terms, hold that Section 154 of the Code postulates the mandatory registration of FIRs on receipt of all cognizable offence, yet, there may be instances where preliminary inquiry may be required owing to the change in genesis and novelty of crimes with the passage of time. One such instance is in the case of allegations relating to medical negligence on the part of doctors. It will be unfair and inequitable to prosecute a medical professional only on the basis of the allegations in the complaint." 

Their Lordships had asked Central /State Govt. to frame guidelines in these regards in consultation with MCI, but till date no one has taken any steps. Their lordships further relied upon the famous judgment of Jacob Mathew as mentioned herein above. The Court gave guidelines as under :

The category of cases in which preliminary inquiry may be made are as under:

a) Matrimonial disputes/ family disputes

b) Commercial offences

c) Medical negligence cases

d) Corruption cases

e) Cases where there is abnormal delay/laches in initiating criminal prosecution, for example, over 3 months delay in reporting the matter without satisfactorily explaining the reasons for delay.

Thus  in Medical Negligence cases, Preliminary enquiry is a must and before that No arrest can be made, even in the era of BNS. 

In the above case also, their Lordships relied upon the Celebrated judgment of Hon’ble Supreme Court (3 Judges bench) ,  in the case of Jacob Mathew v/s. State of Punjab (AIR 2005 SC 3180 = 2005(6) SCC 1), itself has given clear cut guidelines on arrest of Doctors in case of Medical Negligence Cases. Please see the following link.

http://judis.nic.in/supremecourt/imgs1.aspx?filename=27088

In this case  Sec304A was applied against the Doctors and after going through the law of Negligence on this Point and after considering various legal texts, their lordships observed :

48. ….(5) The jurisprudential concept of negligence differs in civil and criminal law. What may be negligence in civil law may not necessarily be negligence in criminal law. For negligence to amount to an offence, the element of mens rea (criminal intent) must be shown to exist. For an act to amount to criminal negligence, the degree of negligence should be much higher i.e. gross or of a very high degree. Negligence which is neither gross nor of a higher degree may provide a ground for action in civil law but cannot form the basis for prosecution.

(6) The word “gross” has not been used in Section 304-A IPC, yet it is settled that in criminal law negligence or recklessness, to be so held, must be of such a high degree as to be “gross”. The expression “rash or negligent act” as occurring in Section 304-A IPC has to be read as qualified by the word “grossly”.

Regarding Arrest of Doctors, it has been observed :

“52. …we propose to lay down certain guidelines for the future which should govern the prosecution of doctors for offences of which criminal rashness or criminal negligence is an ingredient.

i) A private complaint may not be entertained unless the complainant has produced prima facie evidence before the court in the form of a credible opinion given by another competent doctor to support the charge of rashness or negligence on the part of the accused doctor.

ii.) The investigating officer should, before proceeding against the doctor accused of rash or negligent act or omission, obtain an independent and competent medical opinion preferably from a doctor in government service, qualified in that branch of medical practice who can normally be expected to give an impartial and unbiased opinion applying the Bolam test to the facts collected in the investigation.

iii.) A doctor accused of rashness or negligence, may not be arrested in a routine manner (simply because a charge has been levelled against him).

iv.) Unless his arrest is necessary for furthering the investigation or for collecting evidence or unless the investigating officer feels satisfied that the doctor proceeded against would not make himself available to face the prosecution unless arrested, the arrest may be withheld.”

This Celebrated judgment has been followed and referred to by all the Courts thereafter.Also See A.S.V. Narayanan Rao V/s. Ratnamala & ors. You may see following the link :

http://judis.nic.in/supremecourt/imgs1.aspx?filename=40762

In another celebrated and much referred judgment of Apex Court Martin F. D’Souza Vs. Mohd. Ishfaq, AIR 2009 SC 2049, wherein the Apex Court held as under:

“A medical practitioner is not liable to be held negligent simply because things went wrong from mischance or misadventure or through an error of judgment in choosing one reasonable course of treatment in preference to another. He would be liable only where his conduct feel below that of the standards of a reasonably competent practitioner in his field"

               Remedy for action U/Sec.105 and 106

On the other hand, Sec.106 itself is a Bailable offense. But technically, the above referred guidelines of Hon. Apex Court are in respect of 106 (earlier Sec.304-A), but the judgment of Lalita Kumari (supra) is applicable in Sec.105 (earlier Sec.304 as well as Sec.304-A.) Thus, in my opinion, the Doctors can move for anticipatory Bail or can approach Hon. High Court U/Sec.226 r/w Sec.482 of Cr.P.C. for quashing of FIR when charges U/Sec.105 are imposed. But at times Hon' High Court asks to apply for anticipatory bail and if that is refused then to approach high Court.  In the States like Uttar Pradesh, there is no provision of anticipatory Bail, in such cases, approaching Hon’ble High Court is the only remedy.

It is also to be remembered there may be some cases, where Doctors might have done some Acts that may attract Sec.105. So also a lot depends upon the facts of each independent case. Further civil remedies for claiming compensation against the Doctors may be exercises independently. In any of such cases first approach the expert Lawyer for further steps.

Removal of a wrong charge :

As mentioned earlier, it is the prerogative of the investigation authorities to apply the section. But previously U/Sec.216 of Cr.P.C., it was  the right of the Courts to alter /amend /remove such charge during the trail, before the pronouncement of the judgment. Now the CRPC has been replaced with Bharatiya Nagrik Suraksha Sanhita and now Sec. 239 deals with the alteration of Charge.

 

 Adv. ROHiT ERANDE. ©

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