Delhi State Commission Holds Dr Lal Path Labs Liable For Erroneous Test Reports; Confirms Compensation Of Rs. 3.5 Lakhs

Brief facts:

On the advice of Dr. Neeru Gera of Max Healthcare hospital, the complainant got his blood test done from Dr. Lal Path Labs ('Lab') on 17.05.2011. Some of the results regarding urea creatinine serum, alkaline phosphate and phosphorus serum were far beyond normal range. Thereafter, the complainant also got the same tests done from Max Super Speciality hospital, Saket on the advice of a doctor and as per the second report, all results were normal. Accordingly, the complainant issued a legal notice to the lab for abnormal results indicating high values when all results were normal. The lab then requested the complainant to conduct a fresh blood and urine test and give a fresh report to which the complainant denied as he lost faith in the lab.

The complainant further stated that he got his tests done from two other independent laboratories namely Dr. Dangs Laboratories and Religare SRL Laboratories Ltd where also the reports were normal. A complaint was then filed by the complainant before the Delhi District Commission praying for appropriate compensation.

The district commission found that the values given by Dr. Lal Path labs in its report are astronomically different and are at variance with the values given by the other two labs in their reports. Hence, the commission allowed the complaint on account of defective and erroneous tests and granted a compensation of Rs. 3,50,000 to the complainant.

Aggrieved by the order of the District Commission, the lab preferred an appeal before the Delhi State Commission

Submissions of the complainant:

Before the District Commission, the complainant submitted that if the tests carried by the lab are defective and erroneous, then the doctor will automatically prescribe wrong medicines to a patient on the basis of wrong reports which may prove to be fatal. The complainant submitted that initially, the doctor considered the condition of the complainant to be critical and advised immediate hospitalization on the basis of the reports given by Dr. Lal Path labs. However, it is only after the second test done at Max Healthcare that the complainant came to know of his normal condition.

Before the State Commission, the complainant argued that the inaccurate results given by the lab had caused trauma to him and his family. It was further submitted that a wrong test report constitutes deficiency in service and thus prayed for dismissal of the appeal.

Submissions of the Lab:

Before the District Commission, the lab submitted that the request to conduct a fresh test free of cost was denied by the complainant due to which the lab couldn't verify the allegations of the complainant. It was further submitted that all protocols and due diligence was observed while conducting the tests. The lab argued that the difference in the results was due to the time gap of more than 24 hours between the tests at Dr. Lal Path Labs and Max Healthcare.

Before the State Commission, the lab argued that the medical basis of the report was certified by Dr. Vandana Lal (MD Pathology) and there exists no deficiency in service on its part. It was submitted that the variation in results could be due to possible dehydration or vomiting.

Observations of the Commission:

The bench at the outset, compared the results of the test report given by Dr. Lal Path Labs and Max Healthcare which revealed stark anomalies. The bench observed that the lab failed to provide any quality control evidence or technical explanation for such huge discrepancies in the reports. The bench further observed that when multiple test reports from three different laboratories show normal findings contrary to findings given by Dr. Lal Path labs, there is a strong presumption of deficiency in service.

The bench further observed that medical experts/doctors base their treatment on these medical reports which form the basis of proper diagnosis of the disease. It was also observed that when a patient's urea levels are reported at more than ten times triggering emergency hospitalizations, the lab cannot hide behind arguments and shift the blame to the physician or complainant's medical history. Hence, the order of the District Commission holding Dr. Lal Path Labs, liable for deficiency in service, was upheld by the State Commission.

On the issue of compensation, the bench observed that the medical expenses incurred by the complainant are directly relatable to the erroneous report given by the lab which falsely indicated life-threatening conditions. Hence, the compensation of Rs. 3,50,000 as granted by the District Commission was also upheld.

Thus, the appeal was dismissed.

Case Title: Dr. Lal Path Labs vs Mr. Inder Prakash Wadhwa

Case Number: First Appeal 984 of 2014

Advocate for Appellant: V'D Costa

Advocate for Respondent: Aakash Khattar

Date of Decision: 26.05.2025

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