Ambalal D. Bhatt v. State of Gujarat, 1972
In the very famous case of Ambalal D. Bhatt v. State of Gujarat the Supreme Court again explained the concept that a person is liable under Section 304A of the Indian Penal Code only if the principle of causa causans is fulfilled. Here this case is about medical negligence. Here the appellant who was Chemist Incharge in a chemical industry along with five other members were charged under Section 304A of the IPC. They were found to be negligent in manufacturing the solution of glucose which was later consumed by the patients of different hospitals and 13 patients died by the injection of the solution. It was found that the solution contains more lead nitrate than what was permitted. Here the Prabhakaran was the Chief Analyst of the Testing Laboratory. He was found negligent in his part as he did not prepare the solution according to the Drug Control Act. Here the Supreme Court held that the appellant ( Prabhakaran) can not be liable alone. The court further stated that the appellant was not only negligent, here it was also the duty of several other persons to maintain the quality of the solution. Under the principle of the causa causans there is the causal chain that consists of many links(acts), it talks about the act which ultimately contributes to the consequence. Here the action of the appellant was found to be the only one of the causes of all causes. In other words, it can be explained that the appellant action was one of the causes of death and it was found to be insufficient to be the ultimate cause of the death of the 13 persons.