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Patients Entitled to Access Relevant Medical Treatment Data: Madras High Court

Written by : Jayati Dubey

August 11, 2023

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The court's statement serves as a strong prompt for healthcare professionals, underscoring that withholding vital information might lead to professional misconduct and result in potential legal consequences for encroaching upon patients' rights.

In a landmark ruling, the Madras High Court has said patients are entitled to access their relevant medical data and that is a fundamental right. The court's assertion is a powerful reminder to healthcare practitioners that withholding such critical information could amount to professional misconduct and carry potential legal liabilities for infringing upon patients' rights.

In delivering the court's verdict, Justice G R Swaminathan highlighted the seamless integration of the digital age into healthcare and emphasised the ease of maintaining medical information in digital format.

Swaminathan said, "We have moved into the digital age. It should, therefore, not be difficult to store all information in digital mode. A patient is entitled to be furnished all relevant records pertaining to the treatment. This right can be effectuated only if the information is stored digitally."

The court's pronouncement draws attention to Article 19(1)(a) of the Constitution, a provision encompassing the right to receive information. This right, the judge noted, inherently extends to patients, allowing them to be well-informed about their medical care.

Moreover, with the implementation of the Right to Information Act in 2005, government hospitals are now bound to provide patients and their representatives with requested medical information, leaving no room for information concealment.

The court's stance materialised during the hearing of a case involving Jothi from Ramanathapuram district. Jothi's experience exemplifies the complexities and uncertainties of medical care.

Admitted to Mudukulathur government hospital for childbirth in May 2014, Jothi's case took an unfortunate turn when her newborn faced asphyxia-related complications. Subsequent referrals to Paramakudi government hospital and Government Rajaji Hospital in Madurai ensued, but the child tragically passed away on May 20.

The issue of alleged medical negligence prompted Jothi's father to demand accountability from the medical staff and request access to his daughter's medical records under the Right to Information Act.

Failing to elicit a response, Jothi filed a petition with the Madurai bench of the Madras High Court in 2015, seeking not only redressal and action against the medical practitioners and staff but also compensation.

Justice Swaminathan's nuanced understanding of the complexities inherent in medical decisions shines through. He acknowledged that various factors, including asphyxia, can lead to an adverse outcome even after a normal delivery.

He endorsed the initial decision by doctors at Mudukulathur Hospital regarding a normal delivery, cautioning against retrospective blame assignment due to unforeseen complications.

The court's critique of the authorities for failing to provide Jothi with her medical records highlights the significance of transparency and accountability in healthcare. Denying a patient's access to crucial medical information was deemed a violation of her rights, an approach in line with modern standards of patient-centred care.

Recognising Jothi's entitlement to compensation on the grounds of information denial and potential medical negligence, the judge directed the health secretary to ensure the disbursement of compensation within eight weeks. This judicial directive underscores the court's commitment to promptly addressing patients' grievances and holding healthcare institutions accountable.

The Madras High Court's resolute stance reiterates the evolving paradigm of healthcare, where patients' rights, transparency, and ethical medical practice are paramount. This ruling is pivotal in advocating for patient empowerment, underscored by Justice Swaminathan's apt observations and directives.


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