Medical Treatment Outcomes Do Not Break Causation Chain Unless Grossly Negligent or Unforeseeable.

On April 28, 2007, Anoop Sharma sustained grievous injuries, including leg fractures and crush injuries, when his scooter was hit by a bus driven rashly by Respondent No. 4

Sharma underwent four separate hospitalizations between April 2007 and February 2008

During his final admission, he died on February 22, 2008, due to "ileal perforation peritonitis with septicemia and acute renal failure"

The Motor Accident Claims Tribunal (MACT) treated the matter as a death case, awarding ₹8,30,462 with 9% interest, concluding the death was attributable to the accident injuries and medical treatment (specifically the use of painkillers/NSAIDs)

The Insurance Company appealed, contending that the death was too remote from the accident and that the chain of causation was broken

1. Whether the death of the deceased was a foreseeable consequence of the injuries sustained in the accident or if the chain of causation was broken by a novus actus interveniens (intervening act)

2. Whether the administration of NSAIDs (painkillers) during treatment constitutes a supervening cause that absolves the tortfeasor of liability for the death

The court applied the principles of tortious liability and negligence under the Motor Vehicles Act, 1988

It relied on the "But-For" test for factual causation and the "Foreseeability Test" for legal causation as propounded in Overseas Tankship (U.K.) Ltd. v. Morts Dock Engineering Co. Ltd. (The Wagon Mound)

The court invoked the "Eggshell Skull Rule," established in Smith v. Leech Brain Co. Ltd., which requires a defendant to take the victim as they find them

Furthermore, it applied the principle from Webb v. Barclays Bank, PLC and Robinson v. Post Office, asserting that medical treatment necessitated by an original injury—even if negligent (provided it is not "grossly" so)—does not ordinarily break the chain of causation

The court determined that the original accident set in motion a continuous chain of medical dependency

It analyzed the testimony of PW5 (Dr. Seema Singh), who stated that the fatal ileal perforation was likely caused by NSAIDs administered to treat the accident-related fractures

The court found that since pain management is a standard, foreseeable response to crush injuries, the administration of NSAIDs was a natural consequence of the original tort

The court rejected the appellant's argument regarding novus actus interveniens, noting that medical errors or side effects are foreseeable incidents of treatment and do not "eclipse" the original wrongdoing unless they are "grossly negligent" or "completely inappropriate," which was not evidenced here

The court noted that the Insurance Company failed to lead any evidence to prove an independent intervening cause or unusual susceptibility

It held that there was no break in the chain of causation as the death was a foreseeable consequence of the treatment necessitated by the accident

The court ordered the release of the remaining balance of the awarded amount with accrued interest to the claimants (wife, daughter, and mother) as per the original apportionment

The court emphasized that while the Motor Vehicles Act is social welfare legislation, this decision rested on the rational application of established legal principles regarding proximate cause and foreseeability