Delhi State Commission Upholds Finding of Deficiency in Service Against Dr. Lal Path Labs for Erroneous Medical Report; Affirms Rs. 3.5 Lakh Compensation to Complainant
Pranav B Prem
The Delhi State Consumer Disputes Redressal Commission, comprising Justice Sangita Dhingra Sehgal (President) and Ms. Pinki (Judicial Member), upheld the decision of the District Commission which found Dr. Lal Path Labs Pvt. Ltd. liable for issuing erroneous pathological reports. The commission confirmed an award of compensation amounting to Rs. 3,50,000 for the trauma and inconvenience caused to the complainant.
Background
The complainant, on the advice of Dr. Neeru Gera from Max Healthcare Hospital, had undergone blood tests at the laboratory of Dr. Lal Path Labs on 17.05.2011. The test results showed highly abnormal levels for parameters such as urea, creatinine serum, alkaline phosphate, and phosphorus serum. Particularly, the urea level was reported at 189 mg/dL (as against the normal range of 17-43 mg/dL), creatinine serum at 8.39 mg/dL (normal range 0.51-0.95 mg/dL), alkaline phosphate at 144 UL (normal range 30-120 UL), and phosphorus serum at 13.20 mg/dL (normal range 2.8-4.0 mg/dL).
These alarming values led the doctor to suspect a life-threatening condition, prompting an urgent recommendation for hospitalization and dialysis. However, subsequent tests conducted at Max Super Speciality Hospital, Saket, on medical advice, returned normal values for the same parameters. Disturbed by these conflicting reports, the complainant lost faith in Dr. Lal Path Labs and refused their request for fresh testing, opting instead to undergo further tests at two other independent laboratories—Dr. Dang’s Lab and Religare SRL Laboratories Ltd. Both of these reports also confirmed normal results.
Following this, the complainant issued a legal notice to the laboratory, which was replied to by the lab. Unsatisfied with the lab’s explanations, the complainant approached the District Consumer Disputes Redressal Commission seeking compensation for the inconvenience, trauma, and financial loss suffered.
District Commission’s Findings
The District Commission noted the stark discrepancies between the results of Dr. Lal Path Labs and those of Max Healthcare, Dr. Dang’s Lab, and Religare SRL. The Commission held that such glaring differences were unjustifiable and could not be explained merely by dehydration or the time gap between tests, as suggested by the lab. The commission also noted that the laboratory could not produce any credible quality control records or technical justification for such astronomical variations.
It was further observed that the complainant was under no obligation to undergo re-testing at the appellant’s lab, especially after having lost confidence in its services. The Commission concluded that the erroneous report led to unnecessary mental agony, trauma, and emergency hospitalization for the complainant, warranting compensation. Accordingly, a sum of Rs. 3,50,000 was awarded to the complainant.
Appeal Before the State Commission
Aggrieved by the District Commission’s decision, Dr. Lal Path Labs filed an appeal before the State Commission. The laboratory argued that the discrepancies in the reports could have been due to multiple factors such as dehydration, vomiting, the stoppage of “Spirex” tablets by the complainant prior to the second test, or time gap variations. It was also submitted that their lab followed proper quality control protocols and that the reports were certified by Dr. Vandana Lal, MD (Pathology). The lab contended that these variations were within possible physiological changes and that no deficiency in service could be attributed to them.
The complainant, in response, maintained that the erroneous report caused immense mental agony and distress. It was argued that the appellant’s attempt to shift blame to the complainant’s medical condition or treatment history was baseless and that the wrong report itself amounted to a deficiency in service under consumer law.
State Commission’s Observations
The State Commission scrutinized the comparative results and upheld the District Commission’s conclusion that the discrepancies were inexplicably vast and could not be justified on technical or medical grounds. The bench found no merit in the appellant’s explanation regarding the potential effects of dehydration, medication stoppage, or treatment differences, especially in light of the fact that three different reputable laboratories had given consistent and normal findings.
The bench also noted that the argument regarding Spirex tablet cessation was raised for the first time at the appellate stage and had no substantial evidentiary basis to warrant consideration. Additionally, the discharge summary from Max Healthcare explicitly linked the hospital admission to the erroneous report of Dr. Lal Path Labs.
The Commission emphasized that medical reports form the critical basis on which doctors diagnose and treat patients. An inaccurate report, especially one showing life-threatening conditions, can cause not only mental trauma but also lead to unnecessary hospitalization and expenses, as was evident in the present case. The lab, therefore, could not absolve itself of liability by attributing blame to other factors without sufficient proof.
Verdict
The Delhi State Consumer Disputes Redressal Commission found no reason to interfere with the District Commission's findings. It held that Dr. Lal Path Labs had failed to discharge the expected standard of care in pathological testing, resulting in deficiency of service. Consequently, the appeal was dismissed, and the award of Rs. 3,50,000 as compensation to the complainant was upheld. No costs were imposed on the parties.
Appearance
Mr. V. D’Costa, along with Mr. Himanshu Sharma, Counsel for the Appellant.
Mr. Aakash Khattar, Counsel for the Respondent
Cause Title: Dr. Lal Path Labs V. Mr. Inder Prakash Wadhwa
Case No: First Appeal 984 of 2014
Coram: Hon’ble Justice Sangita Dhingra Sehgal [President], Hon’ble Ms. Pinki [Member (Judicial)]
[Read/Download order]
