Professional Negligence

1168056_at_workIn the simplest terms, professionals are persons who have more than an average person’s skill, ability and training in any specific domain. Negligence committed by them in the course of performing a professional function is professional negligence. Generally, if professional negligence has been committed, the person who has been adversely affected by it can seek a legal remedy provided certain conditions are met and established.

Firstly, the professional must have represented that he has certain skills which are beyond that which a lay person has. In addition to this, he should have owed a duty of care to the person who claims he has been harmed, and he must have committed a breach of that duty. There must, of course, be harm caused by the professional’s breach of duty.

Whether or not a professional has breached his duty is determined by comparing the manner he has rendered services to the manner in which a reasonable person, acting in the same professional capacity, would be expected to render services. Specific professions may have guidelines, rules or laws which state exactly what a breach of professional duty would involve, and the standard cannot be lowered. However, if a professional were to represent that he would provide services of a much higher standard than a ‘reasonable’ person would provide, it would be entirely possible for the standards vis-a -vis that particular professional in that case to be raised accordingly.

Remedies for professional negligence could exist under contract law, the law of specific performance, tort law and various statutory laws. For example, Section 5 of the 1925 Legal Practitioner’s (Fees) Act says that lawyers may be liable for professional negligence.1 Theoretically, liability under both tort and contract could lie simultaneously, and a suit could be filed as such. However, since liability under contract arises from a voluntary agreement between the parties to it, and liability under tort law arises from English Common Law principles and case law, there are subtle differences between the two. Also, a claim under contract law could often be hard to prove since contracts with professionals are often implied contracts – few people sign written contracts with professionals they deal with such as their doctors, lawyers and accountants.

Remedies in cases of negligence can be sought at civil courts and, in some cases, in criminal courts.2 In India, it has begun to make sense to seek remedies for professional negligence under the 1986 Consumer Protection Act since the procedure followed by Consumer Dispute Redressal Agencies is, inter alia, not as long drawn out or as fraught with technicalities as the procedure of regular courts. The agencies are empowered to deal with deficiencies3 of professional service and award damages provided the service has not been rendered free of charge or under a contract of personal service.4

Even if the doors of agencies created under the Consumer Protection Act are closed to claimants though, the other avenues to obtain remedies remain open to claimants. It may be possible to challenge clauses in contracts including standard format contracts which limit the liability of professionals in cases of negligence on various bases such as unconscionability. And agreements which completely restrain recourse to legal remedies are void.5

(This article is by Nandita Saikia and was first published at LawMatters.in.)

References:
1. No legal practitioner who has acted or has agreed to act shall, by reason only of being a legal practitioner be exempted from liability to be sued in respect of any loss or injury due to any negligence in the conduct of his professional duties.
2. See Sections 304A, 336, 337, 338, Indian Penal Code, 1860
3. Section 2(g), Consumer Protection Act, 1986
4. Section 2(o), Consumer Protection Act, 1986
5. Section 28, Indian Contract Act, 1872

School Punishment Kills Student

It has been reported that a girl in Delhi died after being punished in the municipal school she attended. Her name was Shanno, and she was eleven years old. Apparently, her teacher made her sit in a position imitating a chicken for two hours in the sun and piled bricks on her back. The girl is reported to have died from a lack of oxygen although the details are not clear.

Much could be said about the teacher’s lack of all good sense and humanity but words would probably do a poor job of describing it. To treat a child in such a manner especially considering that temperatures in Delhi are well over 40 degrees centigrade would require extraordinary cruelty.

The media, in its coverage, seems to have focussed on the dearth of laws to protect a child in such a situation and has spoken of the Delhi High Court and the NCPCC taking a stand against corporal punishment in schools.

It isn’t entirely clear why that should be especially relevant in a case such as this. The Indian Penal Code doesn’t have any shortage of provisions to deal with harming other persons be they children or adults: causing hurt, causing grievous hurt, assault, murder and culpable homicide, among others.

And while it is certainly not a bad idea to have some sui generis legislation in place banning the corporal punishment of children both within and outside schools, it is entirely ridiculous to imply that the absence of such legislation in any way bars awarding punishment to those guilty of assaulting a child.

Even leaving criminal law aside, erring teachers and institutions could always be sued under tort law. The principle of vicarious liability, among other things, would ensure that schools which had such teachers could also be pursued through legal channels.

True, children are often assaulted by school teachers. True, there exists no law which specifically deals with banning corporal punishment. It does not, however, automatically follow that there are no remedies available to children and their parents when teachers act in such an unconscionable manner and assault their students.

Another Incident of Ragging

Every once in a while, the news of a student dying because of ragging hits headlines. Usually, it’s followed by a few debates on the telly after which everyone but those involved in and affected by the issue forget all about it. Until the next time it happens.

On March 16, 2009, the issue came up before the Supreme Court following the death of Aman Kachroo, a student of Dr Rajendra Prasad Medical College, Kangra, Himachal Pradesh. Aman was ragged following which he died. It isn’t entirely clear what exactly it was that caused him to die: he suffered a perforated eardrum and internal injuries but there are queries about whether the doctor who attended to him was negligent in treating him.

In addition to this, Additional Solicitor General Gopal Subramaniam also spoke of the death of a girl student of Agriculture and Engineering College, Bapatla, Andhra Pradesh after allegedly being forced to dance obscenely.

The Supreme Court did not take the issue lightly and Justices Arijit Pasayat and A K Ganguly issued a show cause notice to the Principal and Registrar of the Dr Rajendra Prasad Medical College asking them to explain why contempt proceedings should not be initiated against them for not complying with the court’s directions to prevent ragging.

The notice issued by the Supreme Court also required the Principal and Registrar of the Medical College to state what action was taken after the ragging incident was brought to their notice. In addition to this, the court asked the Medical Council of India to inquire into the allegations of medical negligence against the doctor who treated Aman, and the Chief Secretaries and Directors General of Himachal Pradesh and Andhra Pradesh to file separate affidavits stating what they have done to comply with the court’s earlier directions and what action has been taken against the two institutions as well as against the students who did the ragging.

Justice Arijit Pasayat said in no uncertain terms, “It appears that the concern shown by this court has not been taken seriously by the authorities. Prima facie it is contempt of this court. The directions issued by this court on May 16, 2007 and February 11, 2009 on the basis of the R K Raghavan Committee Report to end the menace have not been complied with. Time has come for cutting off financial age to there institutions which are not complying with the directions.”

Perhaps the possibility of this happening i.e. financial support being cut will actually get institutions to do what they can to stop ragging. The University Grants Commission has also said that it will finalise stringent rules on the issue by the first week of April 2009.

The intervention of the Supreme Court and the measures of the UGC come too late for the students who have alreay lost their lives but, with any luck, they will help others in the future.

References:

The Times of India, The Hindu, IndlawIndiaJournal

Bouncy Castle Case

Sam Harris was injured while playing on a bouncy castle when he was 11 years old (in 2006). He was accidentally kicked in the head by a 15-year-old and now needs round the clock treatment.

The bouncy castle had been hired by Catherine and Timothy Perry for their triplets’ tenth birthday party. Sam got on to it after asking Mrs Perry for permission. He had earlier been playing football in an adjoining field with his father who was also made a defendant in the case which was brought by Sam through his mother, Janet Harris.

The case against Mr Harris was dismissed but the Perrys were held liable for not supervising the children properly especially in light of the fact that the castle came with instructions not to allow rough play on it or mix children of different sizes.

The High Court has given the Perrys permission to appeal. If an appeal is not pursued, Sam is to receive an interim payment of £100,000.