Role of Judiciary in Medical

Profession
Introduction
There are many ways to conceptualize health law. The Health Law
& Justice Program views health law as encompassing not only the
law of health care delivery and financing but all areas of study
that focus on the intersection between law and health: from the
ethics of embryonic stem cell research, to the role of government
in preventing child maltreatment, to occupational health and
safety regulations, to the laws governing elder care and death.
We have grouped our health law courses into four overlapping but
distinct areas of study: health care law, public and population
health law, bioethics, and global health law. Although these are
not the only categories into which health law may be divided, we
think these groupings provide a helpful lens for understanding the
fields multifaceted nature.
Broadly defined, health law includes the law of public health,
health care generally, and medical care specifically. Preserving
public health is a primary duty of the state. Health regulations
and laws are therefore almost all administered at the state level.
Many states delegate authority to subordinate governmental
agencies such as boards of health. These boards are created by
legislative acts.

Role of Judiciary in Medical Profession

Judicial Interpretation
Consumer Protection

of

Medical

Negligence

under

Medical profession is one of the most oldest professions of the

world and is the most humanitarian one. There is no better
service than to serve the suffering, wounded and the sick. Aryans
embodied the rule that, Vidyo narayano harihi (which means
doctors are equivalent to Lord Vishnu). Since long the medical
profession is highly respected, but today a decline in the standard
of the medical profession can be attributed to increasing number
of litigations against doctors for being negligent narrowing down
to medical negligence. Hospital managements are increasingly
facing complaints regarding the facilities, standards of
professional competence, and the appropriateness of their
therapeutic and diagnostic methods.
Negligence is a breach of duty caused by omission to do
something which a reasonable man guided by those
considerations which ordinarily regulate the contract of human
affairs would do which a prudent and reasonable man would not
do.
According to Charles worth & Percy Negligence has three
meaning:
A state of mind, in which it is opposed to intention
Careless conduct

 The breach of duty to take care that is imposed by either

common or statute law.
Medical negligence is defined as the failure to exercise rational
caution and capability during diagnosis and treatment over a
patient in accordance to the prevailing standards in force at that
point of time.
In Bolam v. Friern hospital management committee1, the
test for establishing medical negligence was set. The doctor is
required to exercise the ordinary skill of a competent doctor in his
field. He must exercise this skill in accordance with a reasonable
body of medical opinion skilled in the area of medicine.

In Dr.Kunal Saha v. Dr. Sukumar Mukherjee and Ors 2, the

National Consumer Commission summarized the medical
negligence law as follows:
Real test for determining deficiency in service
Whether there was exercise of reasonable degree of care?
The degree of standard or reasonable care varies in each
case depending upon expertise of medical man and the
circumstances of each case.
Medical profession has been brought under the Section 2(1) (o) of
CPA, 1986. In a significant ruling in Vasantha P. Nair v Smt.
V.P.Nair I3, the national commission held a patient is a
consumer and a medical assistance was a service. A doctor is
1 1957
2 1st June, 2006
3 1991

held liable for only his acts (other than cases of vicarious
liability). Vicarious liability arise in case of government hospital
though doctor responsible but hospital has to pay the
compensation.
It is well known that a doctor owes a duty of care to his patient. A
doctor can be held liable for negligence only if one can prove that
she/ he is guilty of a failure that no doctor with ordinary skills
would be guilty of if acting with reasonable care.
In Parmanand Kataria v Union of India 4, Supreme Court
make it obligatory that every doctor, at the governmental
hospital or elsewhere, has a professional obligation to extend his
services with due expertise for protecting life.
Incidence of medical negligence can also decide by medical
council of iIdia. Medical council of India is a statutory body deal
with high standards of medical education and recognition of
medical qualifications in India. It registers doctors to practice in
India and promote the health and safety of the public. In many
cases national commission accept the credibility of councils
verdict in medical negligence.Medical council of India guided by
the Medical Council Act 1956.

Extended ambit of medical negligence

The National Commission as well as the Apex Court in catena of
decisions has held that the doctor is not liable for negligence
because of someone else of better skill or knowledge would have
prescribed a different treatment or operated in a different way.
He is not guilty of negligence if he has acted in accordance with
the practice accepted as proper by a reasonable body of medical
professionals.
4

In Supreme Court land mark decision Indian Medical

Association v V.P. Shantha and Others III 5 C.P.J laid down
certain guideline for medical negligence and define efficiency of
consumer protection. It has held certain exception like:
Service rendered to patient in (free of cost or charity) by a
medical professional would not fall under the definition of
service under consumer protection act1986.
Service rendered by a doctor under contract of personal
service was not covered in consumer protection act 1986.
Also held that there are three tiers of disputes redressal forum
they are at the lowest level are the District Consumer Disputes
Redressal Forum, which entertain compensation claims up to
Rs.20 Lakh. At the next level are the State Consumer Disputes
Redressal Forums (one in each state), where compensation
claims between Rs.20 Lakh and Rs. l Crore are made. At the
National Forum, claim of over Rs. 1 Crore are lodged. Those
dissatisfied with the judgment of the lower forum can appeal to a
higher forum. The final court of appeal is the Supreme Court.

Essential Components of Medical Negligence

On basis of various judicial pronouncements essentials of
'Medical Negligence' as are discernible, in brief and in so far as
it is relatable to the medical profession, are as under:
(i) The Doctor must owe a duty of care to the patient.
5 1995

(ii) The Doctor must have made a breach of that duty.

(iii) The patient must have suffered damages due to the said
breach.
The Supreme Court in the case of Minu B. Mehta v. B.R.
Nayar6 has held that the right to receive compensation can
only be against a person who is bound to compensate due to his
failure to perform a legal obligation. In many cases doctors have
been held liable for negligent acts, such as removal of a wrong
eye or a kidney, based on pecuniary interest or where minimum
facilities were available.
Absence of any of these requirements can result into endanger
to the patients life. On April 9, 1985, the General Assembly of
the United Nations adopted the guidelines to provide framework
for Governments, particularly those of developing countries. The
legitimate needs which the guidelines are intended to meet
include the protection of consumers from hazards to their health
and safety and availability of effective consumer redress were
first set up in 1986.

What is an accepted medical practice?

It is also called as scientific medical practice. It is a practice
which is mentioned in standard text books or various issues of
leading medical journals or recognized by responsible body of
medical profession.
In cases of medical negligence the outcome of the treatment is
of secondary importance, but the method adopted is of primary
and much greater importance.
In case if doctor fails to follow one of the accepted methods &
instead departs from the conventional course of treatment, the
burden of proof lies upon the doctor to show that whether he
had taken all proper care into account before deciding the
6 1977 (2) SCC 441

depart & he had informed the patient and taken his consent or
not.
There may be one or more perfectly proper standards, and if he
conformed to one of these proper standards, he will not be
considered negligent.
In case of State of Haryana v. Santra7 the court has decided
that in absence of gross mismanagement, liability of gross
negligence will not be succeeded.
Any reasonable man entering into a profession which requires a
particular level of learning to be called a 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. A lawyer does not tell his
client that the client shall win the case in all circumstances. A
physician would not assure the patient of full recovery in every
case. A surgeon cannot and does not guarantee that the result
of surgery would invariably be beneficial, much less to the
extent of 100% for the person operated on. The only assurance
which such a professional can give or can be understood to
have given by implication is that he is possessed, of the
requisite skill 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 skill with reasonable
competence. This is what the entire person approaching the
professional can expect. Judged by this standard, a Professional
may be held liable for negligence on one of two findings either
he was not possessed of the requisite skill which he professed
to have possessed, or, he did not exercise, with reasonable
competence in the given case, the skill which he did
possess.The standard to be applied for judging. Whether the
person charged has been negligent or not, would be that of an
7 2000 (3) SCC 520

ordinary competent person exercising ordinary skill in that

profession.
In Syad Akbar v. State of Karnataka 8 the Supreme Court has
dealt with and pointed out with reasons the distinction between
negligence in civil law and in criminal law. Their Lordships have
opined that there is a marked difference as to the effect of
evidence, viz. the proof, in civil and criminal proceedings. In civil
proceedings, a mere preponderance of probability is sufficient,
and the defendant is not necessarily entitled to the benefit of
every reasonable doubt; but in criminal proceedings, the
persuasion of guilt must amount to such a moral certainty as
convinces the mind of the Court, as a reasonable man, beyond
all reasonable doubt. Where negligence is an essential
ingredient of the offence, the negligence to be established by
the prosecution must be culpable or gross and not the
negligence merely based upon an error of judgment.

Res Ipsa loquitur

The doctrine of res ipsa loquitur means, that the accident
speaks for itself or tells its own story. The normal rule is that it is
for the plaintiff to prove negligence, but, in some cases,
considerable hardship is caused to the plaintiff, as the true
cause of the accident is not known to him, but is solely within
the knowledge of the defendant who caused it. The plaintiff can
prove the accident but cannot prove how it happened (so as) to
establish negligence on the part of the defendant.
For the applicability of the principle should fulfill three essential
conditions:
The opposite party must have been in control of things.
Common knowledge/accepted norms suggesting that the
injury/damage/loss, in itself cannot occur without
negligence.
8 (1980) 1 SCC 30

The cause of incident/injury must be unknown or

unascertainable.

Some of the common instances, where this principle can be

invoked, are operation on a wrong patient or a wrong part of the
body, transfusion of improper blood, leaving some foreign
material in the body, performing an abortion or any other
operation or surgery which is prohibited in law, etc.

Medical Professionals in Criminal Law

The criminal law has invariably placed the medical professionals
on a pedestal different from ordinary mortals. The Indian Penal
Code Act 1860, Section 88 in the Chapter on General Exceptions
provides exemption for acts not intended to cause death, done
by consent in good faith for persons benefit. Section 92
provides for exemption for acts done in good faith for the
benefit of a person without his consent though the acts cause
harm to a. person and that person has not consented to suffer
such harm. There are four exceptions listed in the Section,
which is not necessary in this context to deal with. Section 93
saves from criminality certain communications made in good
faith.
The following statement of law on criminal negligence by
reference to surgeons, doctors etc. and unskillful treatment
contained in Roscoes Law of Evidence (Fifteenth Edition) is
classic:

Where a person, acting as a medical man & c whether licensed

or unlicensed, is so negligent in his treatment of a patient that
death results, it is manslaughter if the negligence was so great
as to ;, amount to a crime, and whether or not there was such a
degree of negligence is a question in each case for the jury. In
explaining to juries the test which they should apply to
determine whether the negligence in the particular case
amounted or did not amount to a crime, judges have used many
epithets, such as culpable, criminal, gross, wicked, clear,
complete. But whatever epithet be used and whether an
epithet be used or not, in order to establish criminal liability the
facts must be such that, in the opinion of the, jury, the
negligence of the accused went beyond a mere matter of
compensation between r subjects and showed such disregard
for the life and safety of others as to amount to a crime against
the State and conduct deserving punishment.

In Kurban Hussein Mohamed Ali Rangawalla v. State of

Maharashtra9dealing with Section 304A of IPC,
To impose criminal liability under Section 304-A, Indian Penal
Code, it is necessary that the death should have been the direct
result of a rash and negligent act of the accused, and that act
must be the proximate and efficient cause without the
intervention of anothers negligence. It must be the causa
causans; it is not enough that it may have been the causa sine
qua non.
The same view has been reiterated in Kishan Chand & Anr. v.
The State of Haryana10
9 (1965) 2 SCR 622
10 (1970) 3 SCC 904

In Juggankhan v. The State of Madhya Pradesh 11, the

accused, a registered Homoeopath, administered 24 drops of
stramonium and a leaf of dhatura to the patient suffering from
guinea worm. The accused had no knowledge of the effect of
such substance being administered and yet he did so. In this
background, the inference of the accused being guilty of rash
and negligent act was drawn against him.
So, the principle which emerges is that a doctor who
administers medicine known to or used in a particular branch of
medical profession impliedly declares that he has knowledge of
that branch of science and if he does not, in fact, possess that
knowledge, he is prima facie acting with rashness or
negligence.
In Dr. Laxman Balkrishna Joshi
v. Dr.Trimbak Bapu
Godbole and Another12, the Court held that a person who
holds himself out ready to give medical advice and treatment
impliedly undertakes that he is possessed of skill and
knowledge for that purpose. Such a person when consulted by a
patient owes him certain duties, viz., a duty of care in deciding
whether to undertake the case, a duty of care in deciding what
treatment to be given or a duty of care in the administration of
that treatment. A breach of any of those duties gives a right of
action for negligence to the patient.
In Indian Medical Association v. V.P. Shantha and Ors. 13 a
three-Judge Bench decision. The principal issue which arose for
decision by the Court was whether a medical practitioner
renders service and can be proceeded against for deficiency
in service before a forum under the Consumer Protection Act,
11 (1965) 1 SCR 14
12 (1969) 1 SCR 206
13 (1995) 6 SCC 651

1986. The court held that professional men should possess a

certain minimum degree of competence and that they should
exercise reasonable care in the discharge of their duties. In
general, a professional man owes to his client a duty in tort as
well as in contract to exercise reasonable care in giving advice
or performing services.
In Poonam Verma v. Ashwin Patel and Ors 14 a doctor
registered as medical practitioner and entitled to practice in
Homoeopathy only, prescribed an allopathic medicine to the
patient. The patient died. The doctor was held to be negligent
and liable to compensate the wife of the deceased, since he
trespassed into a prohibited field and prescribed the allopathic
medicine to the patient causing the death, his conduct
amounted to negligence per se actionable in civil law.
In Achutrao Haribhau Khodwa and Ors. v. State of
Maharashtra and Ors15, the Court noticed that in the very
nature of medical profession, skills differs from doctor to doctor
and more than one alternative course of treatment are
available, all admissible
In State of Harvana and Ors. v. Smt. Santra 16 , Bolams test
has been approved. This case too refers to liability for
compensation under civil law for failure of sterilization operation
performed by a surgeon.

14 (1996) 4 SCC 332

15 (1996) 2 SCC 634
16 (2000) 5 SCC 182

In Jacob Mathew v. State of Punjab and Anr 17, it was not

the case of the complainant that the accused was not a doctor
qualified to treat the patient whom he agreed to treat. It is a
case of non-availability of oxygen cylinder either because of the
hospital having failed to keep available a gas cylinder or
because of the gas cylinder being found empty. Then, probably
the hospital may be liable in civil law but the accused cannot be
proceeded against under Section 304A IPC on the parameters of
Bolam's test.

Opinion of
Constitution

Supreme

Court

in

context

of

The judgment of the Supreme Court in Nilbati Behra State of

Orissa18, case holds that in view of the fundamental right to life
(Article 21 of the Constitution) the Government cannot claim
"sovereign immunity" for liability for the negligence of its
employees.
The right to health and health care is protected under Article 21
of the Constitution of India, as a right to life and reach of which
can move the Supreme Court on High Court through writ
petition. Practice of medicine is capable of rendering great
service to the society provided due care, sincerity, efficiency
and skill are observed by doctors. When doctors performed
their duties towards the patient negligently in a Government
hospital, the servants of the state violated the fundamental
right of the patient, guaranteed under Article 21 of the
Constitution.
Medical profession has its own ethical parameters and code of
conduct. 'Services' of medical establishments are more of
17 AIR 2005 SC 3180
18 AIR 1993 SC 1960

purchasable commodities and the 'business' altitude have given

an impetus to more and more malpractices and instances of
neglect. But the question is, whether, on the whole, branding
the entire medical community as a delinquent community would
serve any purpose or will it cause damage to the patients. The
answer is, no doubt, the later. It is not that measures to check
such dereliction are absent. Victims of medical negligence,
considering action against an erring doctor, have three options.
Compensatory mode - Seek financial compensation before
the Consumer Disputes Redressal Forum or before Civil
Courts.
Punitive/Deterrent mode - Lodge a criminal complaint
against the doctor.
Corrective/ Deterrent mode - Complaint to the State
Medical Council demanding that the doctor's license be
revoked.

Medical negligence in India

Man is the only animal who believes in keeping order in his
world. This was one of the reasons that he invented the
concept of law. Law helped every man who suffered from an
injury due to the acts committed by others, to seek remedy by
means of compensation or punishment to the person
committing that act. It was in this time that the field of
medicine was developing. Since no man is perfect in this world,
it is evident that a person who is skilled and has knowledge
over a particular subject can also commit mistakes during his
practice. Such mistakes in the medical profession may lead to
minor injuries or some serious kinds of injuries and sometimes
these kinds of mistakes may even cause death. In such
situations there arises a need for a remedy to the injured

people so that justice is upheld and this gave rise to the

concept of medical negligence.
Professional negligence, more specifically, medical negligence
is, as the term suggests, relates to the medical profession and
is the result of some irregular conduct on the part of any
member of the profession or related service in discharge of
professional duties. But first of all it is essential for us to
analyze what the terms remedy, legal right, legal duty and
most importantly negligence mean.

Negligence is the breach of a legal duty to care. Thus legal duty

of a person means the duty the law gives to every person to
respect the legal rights of the other. Therefore the legal right of
a person can be defined as the provisions provided by law to
protect the interests of its citizen. We must remember then that
where there is a legal right, there is a legal remedy for it. This is
inferred from the maxim ubi jus ibi remedium.
Medical negligence can be seen in various fields like when
reasonable care is not taken during operations, during the
diagnosis, during delivery of the child, with issues dealing with
anesthesia etc. Since this field is very vast we will limit
ourselves in understanding the basic concepts which are
essential for the negligence to be committed. We shall also look
into the remedies that the law provides to these patients and
on whom the burden of proof lies and when this burden of proof
shifts to the other party. We would also be discussing in the
following pages the defenses used by doctors to rescue
themselves from the liability and also compare all these things

with the English law and also look into the similarities that the
Indian law and English law share.

Component of medical negligence

Winfield stated that a negligent act comprises of three main
components. They are:
Existence of legal duty.
Breach of legal duty.
Damage caused by the breach
In order to understand the correct meaning of medical negligence
it is essential that we carefully analyze these components
because only after we analyze these components will we be able
to understand the remedies that the law provides us.
Existence of legal duty: Whenever a person approaches
another trusting him to possess certain skill, or special
knowledge on a given problem the second party is under an
implied legal duty to exercise due diligence as is expected to
act at least in such a manner as is expected in the ordinary
course from his contemporaries. So it is not that the legal
duty can only be contractual and not otherwise. Failure on
the part of such a person to do something which was
incumbent so, that which would be just and reasonable
tantamount to negligence. Every time a patient visits a
doctor for his ailments he does not enter into any written
contract but there is a contract by implication and any lack
of proper care can make the erring doctor liable for breach of
professional duty.
Breach of legal duty: There is a certainly a breach of legal
duty if the person exercising the skill does something which
an ordinary man would not have done or fails to do that
which an ordinary prudent man would have done in a similar

situation. The standards are not supposed to be of very high

degree or otherwise, but just the relative kind, that is
expected from man in the ordinary course of treatment.
Damages caused by the breach: The wrong, the injury
occasioned by such negligence is liable to be compensated I
n terms of money and the courts apply the well settled
principles for determination of the exact liquidated amount.
We must remember that no hard and fast rule can be laid
down
for
universal
application.
While
awarding
compensation, the consumer forum has to take into account
all relevant factors and assess compensation on the basis of
accepted legal principles on moderation. It is for the
consumer forum to decide whether the compensation
awarded is reasonable, fair and proper according to the facts
and circumstances of the case.
The liability of the person committing the wrong can be of three
types depending on the harm caused by him to the injured
person, they are:
Civil liability: As mentioned before, the person who
possesses special knowledge and skill in a field and uses this
knowledge to treat the other person then he owes a duty of
acre to the other person. If a wrong is committed by him in
this period, then he is liable to pay damages in the form of
compensation to him. In some situation senior doctors or the
hospital authorities can also be vicariously held liable for the
wrongs committed by junior doctors.
Criminal liability: There may be an occasion when the
patient has died after the treatment and criminal case is filed
under section 304A of the IPC of allegedly causing death by
rash or negligent act. The commencement or pendency of
criminal trial would not act as bar to parallel civil
proceedings for recovery of money or a consumer complaint
nor can the same be stayed.

But there are large numbers of cases where criminal law and civil
laws can run side by side. The two remedies are not mutually
exclusive but clearly co-extensive and essentially differ in their
context and consequence. The object of the criminal law is to
punish an offender who committed the negligence but in civil law
the objective is not to punish but to get compensation from the
other person.

Standard of care required in India

There was considerable ambiguity on the standard of care
required to be exercised by medical practitioners in order to
discharge possible criminal liability arising out of their acts or
omissions. Section 304-A of the Indian Penal Code, 1860 [IPC]
prescribes punishment for death due to rash or negligent conduct
of a person. It is under this section that doctors or other medical
practitioners have generally been proceeded against under
criminal law. Even though there is protection given to accidents
caused during performance of lawful acts [Section 80, IPC] and
acts not intended to cause death and done for the persons
benefit by his consent and in good faith [Section 88, IPC], the fear
of criminal liability has been lingering while performance of their
duty even today.

Test used in India

In determining the test for medical negligence and prosecution of
medical practitioners, the Supreme Court of India has also issued
certain guidelines. What goes to the basis of these guidelines is
that once a criminal investigation begins against a doctor, the
loss of reputation is nearly irreversible. It has also been taken
into account that since the nature of work that doctors perform is
one involving public service, it is even more necessary that
certain guidelines be issued in this regard.
Government of India along with the Medical Council of
India should formulate certain rules/regulations etc to
regulate aspects of negligence in medical practice. While
this exercise is pending, the following guidelines must be
kept in mind while prosecuting medical practitioners.
To make a case against a doctor, a private complainant
has to submit evidence of a prima facie case before the
authority taking cognizance of the act. Such authority
must also include credible opinion given by another
competent doctor to support his case.
The investigating officer must also, independently, obtain
an impartial ad unbiased opinion of a doctor who practices
in the same field in the same regard.
The doctor concerned should not be arrested like in a
regular prosecution. He may be arrested if there is a fear
that the doctor will not make he himself available for
investigation.

Conclusion
In India almost every day there is a case of medical negligence
which is seen. It is seen in the big as well as in the small
hospitals, clinics, dispensaries etc. Due to this a number of
people are suffering in our country. The most common type of
medical negligence is seen in operations and during the
delivery of the child etc. a number o cases has been filed
against doctors who negligently leave their surgical
instruments in the body of the patient etc. still a number of
doctors leave their instruments in the stomach of the patient
which could be fatal. In India doctors are treated as gods,
hence when some kind of negligent acts are carried out by
them, they think that it was the wish of god and dont make the
doctor responsible for this. Illiteracy is another big factor that is
not letting our people to know what kinds of wrongs are being
committed in our country. Our country is facing a terrible time
today as the doctors also are taking advantage of poor people
and are making their service sector, a profit oriented sector and
changing their vision from providing good health to gaining
profits from innocent people by asking them to undergo 1000
tests before treating them for a common cold. The environment
in the hospitals like the cleanliness etc is also not maintained
by most of the hospitals not only in the rural region but also in
the urban region which results in the spread of communicable
diseases faster and easier.

The relaxed behavior by the people, by the hospital authorities

and the government officers who check these places has
resulted in the relaxed behavior of the doctors, which is the
main reason that the number of cases of medical negligence is
increasing. In my opinion if the common people with the
support of the government impose rules on these hospitals and
also see to it that these rules are implemented then there is a
chance that the standards of our hospitals would improve and
automatically the skill and knowledge of specialized and
authorized doctors would be used to the fullest. We must also
spread awareness in the rural areas so that poor people dont
get exploited and fight for their rights and ask for the required
remedy from the medical practitioner causing them the harm.

CONTENT
Introduction
Judicial Interpretation of Medical Negligence under Consumer
Protection
Extended ambit of medical negligence
Essential Components of Medical Negligence
What is an accepted medical practice?
Res Ipsa loquitur
Medical Professionals in Criminal Law
Opinion of Supreme Court in context of Constitution
Medical negligence in India
Component of medical negligence
Existence of legal duty.
Breach of legal duty.
Damage caused by the breach
Standard of care required in India
Test used in India
Conclusion

ACKNOWLEDGEMENT
I would like to express my gratitude and appreciation to all those
who gave me the possibility to complete this project. A special
thanks to my teacher, Miss
, whose help,
stimulating suggestions and encouragement, helped me to
coordinate my project especially in writing this report.
I would like to express my gratitude towards my parents for their
kind co-operation and encouragement which help me in
completion of this project.
My thanks and appreciations also go to my colleague in
developing the project and people who have willingly helped me
out with their abilities.

Yasmin Khanam

BIBLIOGRAPHY
Ratanlal and Dhirajlal, Laws of Torts, 24th edition, 2002,
edited by Justice G.P.Singh
The Consumer Protection Act, 1986.
Law of tort, by P.S.A Pillai, Eastern book company.
Law and medical ethics, by Mason and Mc Call Smith, oxford
university press
www.lehalserviceindia
www.indiankanoon,com
www.jestor.com

Project
On
Role of Judiciary in Medical
Profession

Submitted to: Miss

Submitted by: Yasmin Khanam
BA.LLB. (Hons)
IV Year (8th sem)
Section A