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As per case facts, a criminal complaint alleging medical negligence leading to a patient's death was filed against Sanjeevan Medical Research Centre and its doctors. While AIIMS and DHS reports
...found no gross negligence, the DMC found one doctor guilty of professional misconduct for a lapse in administering a test dose. The High Court had quashed the criminal proceedings based on the expert medical opinions. This recall application seeks to revive the criminal proceedings, citing the DMC's findings. The question arose whether the High Court should recall its previous judgment, especially given the DMC's disciplinary findings, and if such findings meet the threshold for criminal culpability. Finally, the High Court dismissed the recall application, stating that the DMC's finding was a limited professional lapse, not gross negligence or recklessness required for criminal liability under Section 304-A IPC. The Court found no error apparent on record, reiterating that disciplinary findings do not automatically translate to criminal culpability.
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