Medical negligence after transplant requires proof of breach of duty, not merely later complications or an adverse outcome.

Post-operative medical negligence is not established by later complications or a fatal outcome after a successful kidney transplant; liability requires proof that the treatment fell below the standard of a reasonably competent professional, with breach of duty and lack of reasonable skill or competence. The Court found that the patient had been managed by qualified nephrologists and surgeons, kept under ICU monitoring, and discharged only after medical assessment, while the appellants' witnesses were not transplant specialists. On that evidentiary basis, the claim of deficient follow-up care failed and no liability was made out.

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Issues: Whether the respondents were guilty of post-operative medical negligence or deficiency in follow-up care in the treatment of the transplant patient.

Analysis: The claim rested on alleged lapses after a successful kidney transplantation, including complaints of pain, cellulitis, abscess, fever, and later complications. The record showed that the patient was treated by qualified nephrologists and surgeons, kept under ICU care, monitored post-surgery, and discharged only after medical assessment. The Court applied the settled principles governing medical negligence, including the need to prove breach of the duty of care, lack of reasonable skill or competence, and that a mere adverse outcome, error of judgment, or failure to save the patient does not by itself establish negligence. The Court also noted that the appellants' medical witnesses were not specialists in kidney transplantation, whereas the respondents relied on expert nephrologists whose evidence supported the treatment course adopted.

Conclusion: The appellants failed to establish post-operative medical negligence or deficient follow-up care, and the respondents were not liable.

Ratio Decidendi: In medical negligence claims, liability arises only when the practitioner's conduct falls below the standard of a reasonably competent professional in that field; a successful procedure followed by later complications or death does not, without proof of breach of duty and lack of reasonable competence, establish negligence.

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