The NCDRC dismissed Fortis neurosurgeons' appeal and upheld a ₹50 lakh award, holding negligence proved on res ipsa loquitur where surgery proceeded without fresh pre-operative investigations and without informed consent, while exonerating the hospital.
The Supreme Court affirmed that a hospital is vicariously liable for the negligence of the doctors and staff it employs, upholding the NCDRC's finding of negligence in the death of a 27-year-old patient. It modified only the quantum, reducing the hospital's share of compensation from Rs 15 lakh to Rs 10 lakh.
A three-judge bench of the Supreme Court held that a prosecution under Section 141 of the Negotiable Instruments Act cannot stand against a director or authorised signatory unless the company itself is arraigned as an accused. Vicarious liability is derivative, and the principal offender must be on the record before secondary liability can attach.
The Supreme Court held that liability under Section 138 of the Negotiable Instruments Act attaches only to the drawer who maintains the account on which the cheque is drawn. A director who signs a cheque on his company's account does not become the drawer in his personal capacity, and cannot be prosecuted unless the company itself is arraigned.
The Supreme Court quashed cheque-dishonour proceedings against an independent non-executive director, holding that mere designation as a director does not attract Section 141 liability. Vicarious liability under the NI Act must be pleaded and proved with specific averments that the director was in charge of and responsible for the company's business.