The Supreme Court has quashed criminal proceedings against a senior anaesthetist accused of medical negligence in connection with the death of a patient following piles surgery at a hospital in Kannur, Kerala. The Court held that the material on record did not disclose the kind of “gross negligence” required to prosecute a doctor under criminal law.
A bench of Justices Pankaj Mithal and Prasanna B. Varale delivered the judgment on May 25, 2026, allowing the appeal filed by Dr. Supriya Kumari M.C.
Background of the Case
According to the prosecution, patient K.P. Muralidhar was admitted to Dhanalakshmi Hospital in May 2002 for piles surgery. After the surgery, his condition allegedly worsened when an analgesic injection was administered by a nurse. He later collapsed and died. The post-mortem report recorded acute coronary insufficiency as the cause of death and also noted an 80% blockage in the left coronary artery.
An FIR was initially registered only against the surgeon. Later, after further investigation, charges under Section 304-A IPC were added against the surgeon, the anaesthetist and the attending nurse. The appellant repeatedly challenged the criminal proceedings before different courts, but the Kerala High Court refused to interfere in October 2024.
The Supreme Court closely examined the expert panel report and the statements of the nurse involved in the case. The bench noted that the nurse had given inconsistent versions regarding who instructed her to administer the injection.
“The statements are giving a totally different version, as such there is absolutely no material having any evidentiary value against the appellant,” the Court observed.
The Court also noted that the anaesthetist had completed her duty hours by 5 p.m. and had left the hospital after ensuring the patient was stable. When complications arose later in the evening, other doctors, including an anaesthesiologist, were available in the hospital.
Referring to the landmark ruling in Jacob Mathew v. State of Punjab, the bench reiterated that criminal negligence by a medical professional requires a much higher threshold than ordinary civil negligence.
The Court said, “What may be negligence in civil law may not necessarily be negligence in criminal law.”
It further held that even if the doctor had advised administration of the painkiller over phone, it could not automatically amount to criminal recklessness.
An important factor considered by the Supreme Court was the earlier finding of the District Consumer Disputes Redressal Forum, Kannur. In 2017, the consumer forum had held the hospital liable but did not fasten liability on the appellant doctor. The deceased’s family challenged only the compensation amount before the State Commission and did not question the doctor’s exoneration.
The Supreme Court said continuing criminal prosecution despite such findings would amount to abuse of the legal process.
Allowing the appeal, the Supreme Court set aside the Kerala High Court’s order and quashed the criminal proceedings pending before the Judicial Magistrate First Class-I, Kannur.
“The prosecution against the appellant… stands quashed and the appellant is discharged from the offences alleged against her,” the bench ordered.
Case Details:
Case Title: Supriya Kumari M.C. v. State of Kerala & Ors.
Case Number: Criminal Appeal arising out of SLP (Crl.) No. 124 of 2025
Judges: Justice Pankaj Mithal and Justice Prasanna B. Varale
Decision Date: May 25, 2026
