Date of filing: 22.01.2013.
Date of disposal: 22.04.2014.
BEFORE THE DISTRICT CONSUMER DISPUTES REDRESSAL FORUM - II:
VIJAYAWADA, KRISHNA DISTRICT
Present: Sri A. M. L. Narasimha Rao, B.Sc., B. L., President
Smt N. Tripura Sundari, B. Com., B. L., Member
Sri S. Sreeram, B.A., B.Com., B.L., Member
Tuesday, the 22nd day of April, 2014
C.C.No.29 of 2013
Between:
Consumer Guidance Society Representing: Chilukoti Prasad, S/o Ramulu (late), Aged about 45 years, Door No.54-19-23, Flat No.2F- 302, Bhanu Towers, 3rd Lane, Jayaprakashnagar, Vijayawada – 520008.
….. Complainant
And
Dr. C. Sai Prasad, M.S. Ortho, Viswa Chakra Orthopadic Hospital, D.No.26/323, Buttaipet, Machilipatnam – 521001, Krishna District.
. … Opposite Party.
This complaint coming on before the Forum for final hearing on 7.4.2014, in the presence of Consumer Guidance Society for complainant; Sri G. Prasad Reddy, advocate for opposite party and upon perusing the material available on record, this Forum delivers the following:
O R D E R
(Delivered by Hon’ble President Sri A. M. L. Narasimha Rao,)
1. This complaint is filed under Section 12 of Consumer Protection Act, 1986 for a direction to the opposite party to pay Rs.10,00,000/- towards compensation and future expenses and to pay cots of Rs.10,000/- on ground of medical negligence.
2. The averments of the complaint in brief are as follows:
The complainant met with an accident on 6.4.2011 and suffered injury to the right leg. He rushed to government hospital in Machilipatnam. As the duty doctor was not available, the complainant was shifted to Viswachakra, the hospital of the opposite party in Machilipatnam. The opposite party assured that the complainant will recover completely from the injury. He advised surgery to the right foot. For that purpose the opposite party had obtained signatures of the blood relations of the complainant on blank papers on 7.4.2011, after performing surgery to the right leg on 6.4.2011. The opposite party charged Rs.10,000/- as total fee but did not issue bill then and told that the bill will be issued at the time of discharge. The complainant’s health had deteriorated and gangrene had developed for want of expertise, skill and standard of treatment. The complainant’s health status became precarious. He and his relatives asked the opposite party to issue discharge summary, with a view to approach an expert for medical opinion. The opposite party had refused to issue discharge summary and case sheet. The complainant left the hospital of the opposite party on 11.4.2011 and went to Dr. Kiran, Kiran’s Vascular Center, Vijayawada. On his reference MRI scan was taken in Global Hospital. On seeing the injury and reports Dr. Kiran told that some blood vessels are cut and vascular surgery must be performed within 24 hours of the accident and that amputation has to be done as the leg was completely afflicted with gangrene. The complainant’s relatives shifted him to NIMS, Hyderabad on 13.4.2011. Several tests were done there. They opined for amputation as there was no life persisted in the blood vessel. This happened only due to negligence of the opposite party. Later the complainant was brought to NRI Hospital, Chinakakani, Guntur District and was admitted there on 14.4.2011. complainant’s right leg was amputated on 22.4.2011 and he was discharged on 30.5.2011. The complainant had lodged a complaint with A.P. Medical Council, Hyderabad against the complainant for his unethical and unfair practice. The experts who gave subsequent opinions stated that vascular surgery must be done within 24 hours of the injury and since it was not done amputation had to be done to save life. The opposite party had told that he performed surgery though he did not perform surgery on 6.4.2011. Since the opposite party was careless, negligent and unfair this complaint is filed for compensation.
2. The opposite party filed version denying the allegations made against him in the complaint and further stating as follows:
This complaint is not maintainable as the complainant had already approached A.P. Medical Council and A.P. Lokayukta. Nagaraju the complainant’s brother brought him to the opposite party hospital at 5.00 pm on 6.4.2011 after taking first aid treatment in Government hospital, Machilipatnam. The opposite party examined the complainant and assessed the general condition and injury status. The injury was a crush injury. The forefoot of the complainant was non-viable. The wound was gaping and contaminated with mud and yellow paint flakes. Dislocated bones were exposed. X-ray was taken. It showed facture and dislocation of foot bones. The opposite party informed the complainant and his attendants about the nature of injury and explained the need for amputation of forefoot. He also advised them to go to higher center for vascular or plastic surgeons second opinion. The complainant and attendants refused both the options. The opposite party explained the seriousness of the wound and obtained consent in writing. Then he proceeded with debridement and bones stabilization using ‘K’ were with the help of ‘C-Arm’ image intensifier machine. It was done within two hours of the complainant’s arrival at the hospital. The opposite party repeatedly informed about non-viable status of the forefoot, loss of sensation in the foot and bluish coloration of toes. He again advised them to go to higher center. While in the ward the patients vital signs were recorded and wound was dressed with sterile dressing. On 11.4.2011 when the opposite party came to ward rounds the patient was found absent. He came to know that the patient left the hospital without informing any one. The opposite party had given the best possible treatment as per the standard medical protocol in the given circumstances using his experience and skill as orthopedic surgeon. The opposite party followed debridement and bones stabilization procedure. If the patient was left without such treatment he would land up in life threatening situation. The wound debridement and percutaneous ‘K’ wire stabilization of dislocated bones was done to prevent the worsening of the injury status. There is no negligence on the part of the opposite party and he was not incompetent to treat the injury of the complainant. The complainant made baseless allegations. The consent letter was not taken on 7.4.2011 as alleged by the complainant and the date of consent was clearly mentioned in the case sheet consent form. During the stay of the complainant in the hospital of the opposite party the temperature of the complainant was normal and even when he was admitted in Kiran Vascular Center, Vijayawada on 11.4.2011. The general condition of the complainant was stable when he was admitted in NRI hospital, Mangalagiri on 14.4.2011 as acknowledged by the OPD slip of casualty and admission slip of Duty Assistant Ortho Surgeon of NRI hospital. They show that there was no deterioration of general condition of the complainant. The allegation that the complainant’s condition became precarious due to 5 days stay in the hospital of the opposite party and that the opposite party did not issue discharge summary to the patient or to his attendants is not true. There is no deficiency on the part of the opposite party and the complainant is not entitled to the reliefs asked for.
3. The complainant himself is examined as PW.1. He also examined his brothers as PWs.2 and 3 who were said to be present in the hospital of the opposite party during the period of treatment. The opposite party examined himself as DW.1. He also examined one Dr. A.V. Seshu Kumar and Dr. B.V. Ramana as Dws.2 and 3. Exs.A1 to A22 are marked on behalf of the complainant and Exs.B1 to B23 are marked on behalf of the opposite party.
4. Heard the arguments advanced by the learned counsel for both the parties. Both parties filed written arguments.
5. The points that fall for determination are:
- Whether there is any negligence on the part of the opposite party in giving treatment to the complainant and in giving advices to him while in the hospital of the opposite party?
- Whether the complainant is entitled to amounts claimed?
Point No.1:
6. The complainant met with an accident on 6.4.2011 and suffered bleeding injury on the right foot with compression of nerves. The complainant was initially taken to Government Headquarters Hospital, Machilipatnam and as the duty doctor was said to be not available the complainant was shifted to the hospital of the opposite party in Machilipatnam. The complainant was admitted in the hospital of the opposite party on 6.4.2011. PWs.2 and 3 were present with the complainant during his stay in the hospital of opposite party. There is no dispute on these facts. According to the complainant the opposite party did not give proper advice and did not give proper treatment to the crush injury he suffered and ultimately it led to below knee amputation of right leg of the complainant. The complainant was in the hospital of the opposite party from 6.4.2011 to 11.4.2011. According to the complainant the opposite party said to have performed surgery but did not perform any surgery. The opposite party had stated that he performed debridement of the contaminated wound and bone stabilization using ‘K’ wire. The opposite party had given the pictorial presentation of such process in the material filed by him on 1.4.2011. It is doubtlessly an operation involving opening of the injury, debridement (removal of debris), cleaning of the injury with saline or antibiotic solution and bone stabilization using ‘k’ wire. The photograph taken of the injured foot of the complainant would show the nature of damage caused to the foot due to crush injury and need for immediate treatment at least to avoid development of infection by following the debridement procedure. If it is not done immediately after the patient is brought to the hospital, there is every likelihood of the development of infection due to contamination. Therefore debridement cannot be considered as unnecessary. There is absolutely no material placed by the complainant to show that the process of debridement and bone stabilization using ‘K’ wire are defective. No medical opinion is obtained to show any incorrect procedure followed by the opposite party.
The opposite party filed some medical literature. A few relevant extracts are given below:
“Examination of neurovascular structures in the area of the fracture and distally is a vital part of the evaluation. Circulation is noted by pulse examination, the warmth and color of the limb, capillary refill, the filling of veins, and ABI testing. Recall that a malaligned limb due to a displaced fracture or unreduced dislocation may demonstrate signs of vascular insufficiency and that realigning the limb to a more appropriate position may provide a return of blood flow to the limb once the vessel is unkinked. If realigning the limb does not improve circulation, then a vascular injury should be suspected and investigated. Never assume that the pulse deficit is caused by vascular spasm. Doing so may lead to catastrophic complications and/or legal ramifictions. An expanding hematoma or pulsatile bleeding likely represents an arterial injury”.
“The treatment of open fractures has long been considered an orthopaedic emergency. The rationale has been that it is imperative to debride and irrigate the wound to minimize the bacterial load to minimize the risk of infection. There has been much made of the time to debridement as being critical, with 6 hours after injury to debridement considered something of an important deadline to meet. Certainly it makes little sense to needlessly delay surgical debridement of these wounds in patients who are physiologically ready for the operative suite.”
“Surgeons must use their best judgment and experience when treating each patient with an open fracture. The individualization of treatment is the cornerstone of treatment.”
“Antibiotics are not advised as a substitute for debridement and the aggressive removal of necrotic and/or contaminated material.”
“After thorough meticulous debridement of all foreign debris and necrotic material, irrigation of wound is performed. Irrigation serves to reduce the bacterial count, float out remaining debris and cleans the wound of hematoma to better visualize the remaining tissues.”
Of “Two vital components of open fracture treatment are restoration of the bony anatomy and skeletal stabilization. Restoring the rotational and angular alignment, and particularly axial length of diaphyseal and metaphyseal fractures has many benefits for expediting healing of the soft tissue injury. Fracture reduction restores appropriate spatial relationship of arteries, veins, and lymphatic channels, unkinking both large and small caliber conduits, improving perfusion and circulation to the injury zone. Peripheral motor, sympathetic and parasympathetic nerves function optimally when decompressed, and contribute to initiation of appropriate immune response and healing. Adequate soft tissue tension also substantially facilitates later reconstructive procedures and internal fixation of provisional fixation is selected primarily. Finally, dead space management is most adequately achieved with anatomic myotendinous and facial plane tension. Minimizing motion of fracture fragments is also important, and decreases persistent soft tissue injury and exaggerated inflammatory mediator release. Both realignment and stabilization allow for immediate vascular inflow, delivering mononuclear and polymorphonuclear cells, as well as antibodies and antibiotics to the compromised tissues (Figure 10-4). Aside from the local benefits, fracture stabilization allows for decreased patient pain, permits mobilization out of recumbency, and minimizes the difficulty with subsequent diagnostic tests”.
(Above are from Rockwood and Green’s ‘Fractures in Adults’ – Sixth Edition)
7. The complainant filed some medical records from the hospital of Dr. Kiran; NIMS, Hyderabad and the NRI hospital, Hyderabad. The complainant was seen by Dr. Kiran, Vascular Surgeon on 11.4.2011 and 12.4.2011 as per the medical record Ex.A3 given by Kiran’s Vascular Surgery Center. In this document there was initial observation without full details. No discharge summary was obtained from Dr. Kiran. Later the complainant went to NIMS, Hyderabad on 13.4.2011 detailed history is noted in the op medical record Ex.A15 issued by NIMS, Hyderabad. After noting down the history the doctors at NIMS had given some details on observing the wound. They have noted right foot was cool and (not legible) with blisters over dorsum of foot, crushed injury over the medial aspect of right foot with exposed bone muscle, soft tissue and ‘K’ wire, blisters and oedema present. There are further observations that in view of advanced ischemia of right foot, vascular reconstruction procedure is not advised. It was further mentioned that vascular surgeon to be consulted regarding vascularity below ankle level. It is then noted that the case seen by Dr. Chandra Sekhar. There was an advice for regular dressing with EUSOL and no orthopaedic intervention was needed at that stage and consultation of PS (Plastic surgeon). It was mentioned that there was no sensation in the foot both on plantar or dorsal aspects; that sensation at ankle leval that there was no bleeding from pinpricks and oedematous fluid from foot. In the advice it was mentioned that foot salvage is not possible in view of absence of sensation and vascularity and then the patient was referred back to orthopaedic surgeon for further management.
8. The complainant went to NRI general hospital on 14.4.2011 and he was in that hospital till 30.5.2011. Below knee amputation of right leg was done in NRI hospital on 22.4.2011. The photocopies filed under Ex.A18 are not fully legible. In these observations made by NRI hospital under Ex.A18 we find one observation that ‘K’ wire in situ and there were signs of gangrene in the right foot. It also appears from Ex.A15 that there were signs of gangrene blackish in the middle foot and loss of sensation. The tibial artery pulsation was feeble but palapable. From this it is clear that by the time the patient went to NRI general hospital on 14.4.2011 there were signs of gangrene in the middle foot area of right leg. The treatment given from 14.4.2011 to 22.4.2011 are not noted in the document filed by the complainant under Ex.A18. It is not known why seven days time was taken by NRI hospital to perform below knee amputation, when gangrene was noticed on 14.4.2011 itself. The complainant is not finding fault with NRI hospital. The complainant does not find fault with NIMs or Dr. Kiran, vascular surgeon for not proceeding with amputation of right foot. The learned society representing the complainant argues that the opposite party ought to have proceeded with amputation of right forefoot without waiting for the consent of the complainant. His argument is based on the immediate need for surgery to avoid development of gangrene which would eat away the remaining limb and ultimately the life. If the doctor who is treating the complainant is bound to proceed with amputation irrespective of consent of the complainant, the same would apply to Dr. Kiran and doctors in NIMs hospital and also doctors in NRI General Hospital where the amputation was not done for seven days after admission. We are not ready to accept the contention of the complainant that the doctor can proceed with amputation without waiting for consent of the complainant. No medical practitioner will have such liberty particularly when amputation of a part of lower limb will have social and economic consequences affecting the injured person.
9. The complainant’s main contention is that the complainant and his attendants were not informed that the opposite party had done only debridement procedure and did not carry out any surgery for reconstruction of foot or that the complainant needed immediate fore foot amputation. On the other hand the opposite parties says that he did only debridement procedure which was essential at that point of time and he advised the complainant and the attendants to go to higher center or vascular surgeon for second opinion as the complainant needed amputation of right foot.
10. The orthopaedic surgeons would decide whether to go for salvage of the injured part or amputation basing on several factors including the consent of the injured and MESS score (Mangled extremity – amputation – salvage score). MESS scoring is done to know whether to choose salvage or amputation. MESS score is based on type of characteristic of wound, sharp group of the patient, ischemia and age of the patient. If the score is seven or above amputation is advised. Still as per the literature filed several patients do not agree for amputation. In such patients secondary amputation may be carried out depending on the nature of injury and speed of recovery. The medical literature filed by the complainant contains the criteria to know MESS score. In case of moderate crush injury the type character is noted as medium energy with score two. The complainant’s injury does not fall under massive crush criteria in which crush injuries occur in logging, railroad, oil rig accidents. BP was found to be stable in the complainant. Therefore under shock group the score will be zero. If there was no pulse by Doppler test ischemia group will be moderate with score of 2. The total score does not appear to be more than 6 as at the time of admission. This is only for an approximate assessment to know the position of the patient as at the time of admission. We are conscious that we are not medical men to make such assessments with any certainty. When the opposite party had stated that he advised the complainant for amputation of fore foot we feel that MESS scoring is of no significance in deciding the dispute.
11. The other medical officers namely Dr. Kiran or doctors from NIMS or NRI hospital did not furnish any opinion in writing in their medical record to show that there was possibility of vascular restoration when the patient was in the hospital of the opposite party and that opportunity is lost because of the time taken in that hospital. No doubt vascular reconstruction shall be done soon after initial debridement and bone stabilization. When the complainant himself had stated that fore-foot was nonviable, it implies that restoration was not practicable in the fore foot of the complainant. Though the complainant had stated that the other doctors had opined that the complainant had to undergo amputation below knee because of the stay in the hospital of the opposite party for five days, no such material is placed before us to support the complainants contention. Therefore we cannot readily accept such contention of the complainant.
12. The complainant stressed the point relating to the opposite party obtaining signatures of PWs. 2 and 3 on the consent form. According to the complainant the signatures of his brothers PWs. 2 and 3 obtained on partially blank printing consent form on 7.4.2011 though the operation was done on 6.4.2011 and the complainant and his brothers were not informed about the non-viability of the foot or need for amputation. PWs.2 and 3 were examined after all other witnesses are examined on complainant’s side as well as on the side of opposite party. The reason for examining them was given by the complainant in his affidavit filed in support of the application in that regard, as an observation made by the Ethics Committee of A.P. Medial Council that the opposite party had performed debridement procedure after taking consent. The copy of consent form was filed by the opposite party along with other documents on 26.6.2013 when affidavit of the opposite party was filed as deposition. The copy of consent form is contained in Ex.B2. That form does not show that it was obtained on 7.4.2011. The complainant had met with an accident at about 1 PM on 6.4.2011. He came to the hospital of the opposite party in the evening and the opposite party had seen him at 6 PM. Debridement has to be done as early as possible preferably within six hours as per observations made in the medical literature referred to above. So there was urgency and the opposite party would naturally take quick decisions and may have taken the signatures on the consent form hurriedly. After all the consent is only for debridement and not for amputation. What was done basing on consent form is not proved to be either objectionable or unnecessary. No medical practitioner may say that debridement was unnecessary considering the nature of the wound suffered by the complainant. Therefore the contention raised by the complainant as regards signatures taken from PWs.2 and 3 on the consent form is of no material importance. We cannot readily accept the statements of PWs.2 and 3 who are no other than the brothers of the complainant examined after production of entire remaining evidence of both parties. We do not have strong ground not to accept the statement of the opposite party that he informed the complainant and the attendants about the need for amputation and the need for debridement procedure. Therefore we do not find fault with the opposite party as regards taking the signatures of PWs.2 and 3 on the consent form.
13. The complainant remained in the hospital of the opposite party for 5 days. He left the hospital on 11.4.2011 admittedly without discharge by the opposite party. If this five days time taken is the crucial delay which led to amputation below knee level instead of amputation of fore-foot or at ankle level, there must be some medical opinion to support such plea. As observed above no medical opinion is obtained to show that the stay of five days in the hospital of the opposite party had resulted in amputation of leg below knee. Amputation was inevitable. If five days delay was counted we must also count the remaining 11 days up to 22.4.2011 when amputation was done. Why there was such delay in NRI hospital is not explained and why the complainant did not undergo amputation at NIMs is not explained. These factors would indicate high probability that the complainant and his relatives were not willing for amputation, may be with the fond hope of salvage of the right foot. Ultimately when NRI hospital informed that not performing amputation would be a threat to the life, the complainant may have agreed for amputation and so it was done on 22.4.2011. Therefore we cannot readily say that the opposite party had retained the complainant in his hospital till 11.4.2011 without informing about the need for amputation. Consequently we are of the opinion that the complainant has not established the negligence or dereliction of duties on the part of the opposite parties. Therefore the opposite party is not found to be deficient in service.
14. The learned counsel for the complainant relied upon the rulings in V. Krishna Rao Vs. Nikhil Super Speciality Hospital, 2010 (3) CPR (SC) 101; D. Pampa Pathi (dead) through LRs. Vs. H.V. Dayanand, 2012 (1) CPR (NC) 137 and T. Rama Rao Vs. Vijaya Hospital, 2008 (2) CPR (NC) 16. In the Krishna Rao case the Apex court had observed that before forming an opinion that expert evidence is necessary, the Fora under the Act must come to a conclusion that the case is complicated enough to require the opinion of an expert or that the facts of the case are such that it cannot be resolved by the members of the Fora without the assistance of expert opinion and that no mechanical approach can be followed by the Fora. Their Lordships had further observed that in a case when negligence is evident, the principle of ‘res ipsa loquitur’ operates and the complainant does not have to prove anything and in such case it is for the respondent to prove that he has taken care and done his duty to repel the charge of negligence. In the present case we do not find such ‘res ipsa loquitur’ factor.
15. In the other two rulings cited the cases are decided on facts and no general principle was laid down. Each medical case shall be decided on its own facts. No objective conclusion can be deduced.
16. The learned counsel for the opposite party cited the rulings in
- S.P. Chengalvaraya Naidu (Dead) By Lrs Vs. Jagannath (dead) by Lrs. And others, 1994 (1) SCC 1.
- Dr. C.P. Sreekumar Vs. S. Ramanujam, 2009 (5) ALD 93 (SC).
- Kusum Sharma and others Vs. Batra Hospital and Medical Research center and Oters, 2010 (2) ALD 89 (SC).
- Jocob Mathew Vs State of Panjab and Another, 2005 (6) SCC.
- A.P. State Road Transport Corporation and Others Vs Abdul Kareem, 2005 (6) SCC 36.
- Patan Saidani Vs Superintending Engineer, APEPDCL, F.A.No.5/2013, A.P. State Commission, dated 4.7.2013.
The first case is a civil case wherein it was held that a decree obtained by playing fraud is liable to be set aside. We do not find its application to the fact of the present case. In Dr. C.P. Sreekumar case it was observed that the burden is largely on the complainant to establish medical negligence and mere statement by the complainant is not sufficient. In Kushan Sharma case the Apex court observed that as long as the doctor performed his duties and exercised ordinary degree of professional skill and competence, they cannot be held guilty of medical negligence. Jocab Mathew is a case based on allegation of criminal medical negligence. It was explained in Krishna Rao case.
The National Commision had depricated the Forum hopping in A.P.S.R.T.C Vs Abdul Kareem cited above. Patan Saidani case is about maintainability of complainant when Lokayukta had decided the issue involved. These two cases have no application. Report to Medical counsel is not for granting cognizance primarily. No government machinery is involved in the present case as to attract the jurisdiction of Lokayukta. Lokayukta had not decided the issue involved.
Point No.2:
17. In view of the answer on point no.1 the complainant is not entitled to any relief. We are not inclined to burden the complainant with costs.
18. In the result this complaint is dismissed without costs.
Dictated to steno, N. Hazarathaiah, transcribed by him, corrected by me and pronounced by us in the open Forum, this the 22nd day of April, 2014.
PRESIDENT MEMBER MEMBER
Appendix of evidence
Witnesses examined
For the complainant: For the opposite party:
Chilukoti Prasad – PW.1 Dr. C. Sai Prasad - OP.
(by affidavit) DW – 1, (by affidavit).
Documents marked
On behalf of the complainant:
Ex.A1 06.04.2011 Original copy of consultation fee receipt issued by OP.
Ex.A2 06.04.2011 Original copy of prescription slip issued by OP
Ex.A3 X-ray
Ex.A4 06.04.2011 Original copy of blood report issued by Swtha Diagnostic Center.
Ex.A5 X-ray
Ex.A6 06.04.2011 Photocopy of cash bill issued by Red Cross Blood Bank.
Ex.A7 06.04.2011 Photocopies of medical bills.
Ex.A8 07.04.2011 Photocopy of cash bill issued by Red Cross Blood Bank.
Ex.A9 07.04.2011 Original copy of blood report issued by Swtha Diagnostic Center.
Ex.A10 08.04.2011 Photocopies of medical bills.
Ex.A11 08.04.2011 Photocopy of x-ray bill
Ex.A12 11.04.2011 Photocopy of prescription bill.
Ex.A13 11.04.2011 Original copy of Kiran’s vascular surgery center document
Ex.A14 11.04.2011 Photocopy of CTA scan report.
Ex.A15 13.04.2011 Reports issued by NIMS, Hyderabad.
Ex.A16 02.07.2011 Original copy of OP card of NRI hospital.
Ex.A17 22.04.2011 Photocopy of wound certificate.
Ex.A18 30.05.2011 Discharge summary.
Ex .A19 11.07.2011 Original physically handicapped certificate.
Ex.A20 16.02.2012 Photocopy of legal notice got issued by complainant to Ops.
Ex.A21 06.03.2012 Photocopy of reply letter issued by Op to complainant’s counsel.
Ex.A22 31.03.2012 Photocopy of rejoinder got issued by complainant to OP.
On behalf of the opposite party:
Ex.B1 18.06.2013 Notarized copy of letter issued by Medical Superintendent, to Sri PSRK Prasada, Advocate and reply letter.
Ex.B2 Notarized copy of consent form, anaesthesia notes; accident register, medical notes etc.
Ex.B3 05.01.2012 Notarized copy of letter issued by complainant to The Registrar, A.P. Medical Council.
Ex.B4 18.05.2011 Notarized copy of affidavit of complainant before Hon’ble Ethics Committee of APMC.
Ex.B5 12.07.2012 Notarized copy of reminder letter to the Registrar, A.P. Medical Council.
Ex.B6 07.09.2012 Notarized copy of reminder letter to the Registrar, A.P. Medical Council.
Ex.B7 21.09.2012 Notarized copy of case copy of A.P. Medical council against the complainant.
Ex.B8 Notarized copy of affidavit of opposite party before Hon’ble Ethics Committee of APMC.
Ex.B9 30.10.2012 Notarized copy of letter issued by complainant to the Registrar, Institution of Lokayukta of A.P.
Ex.B10 Notarized copy of affidavit of opposite party before Hon’ble Andhra Pradesh Lokayukta.
Ex.B11 Notarized copy of MVOP.695/2011 before Motor Accident’s Claims Tribunal.
Ex.B12 Notarized copy of chief affidavit of petitioner in
MVOP. 695/2011 before Motor Accident’s Claims Tribunal.
Ex.B13 Notarized copy of Deposition of complainant in MVOP. 695/2011 before Metorpolitan Sessions Judge cum II Addl. District Judge, Vijayawada.
Ex.B14 Notarized copy of Rockwood and Green’s Fractures In Adults, Sixth Edition.
Ex.B15 Notarized copy of Campbell’s Operative Orthopaedics, Volume.3, Eleventh Edition.
Ex.B16 Notarized copy of Indian Journal of Orthopadics, Vol.36, No.3, July 2002.
Ex.B17 Notarized copy of Trauma, Instructional Course Lectures.
Ex.B18 Notarized copy of Watson – Jones, Fractures and Joint Injuries.
Ex.B19 Copy of opinion letter issued by OP to Dr. M. Bhavani Shankar, Gudivada.
Ex.B20 Notarized copy of accident register.
Ex.B21 Notarized copy of police intimation.
Ex.B22 Notarized copy of inpatient register.
Ex.B23 25.09.2013 Photocopy of decision of AP Medical Council.
PRESIDENT