Supreme Court On Medical Negligence: NCDRC Cannot Create A New Case Beyond Pleadings

Introduction

The Supreme Court of India, in Deep Nursing Home and Another v. Manmeet Singh Mattewal and Others (2025 INSC 1094), delivered on 9 September 2025, clarified an important principle of consumer jurisprudence that adjudicatory forums cannot travel beyond the pleadings of the parties and invent a new case altogether. This ruling not only reiterates judicial discipline in consumer disputes but also underscores the scope and limits of liability in cases of alleged medical negligence. The Court set aside concurrent findings of the State Consumer Disputes Redressal Commission (SCDRC) and the National Consumer Disputes Redressal Commission (NCDRC), which had earlier held doctors and the nursing home liable in varying degrees.