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Mention your qualifications, training, experience, expertise etc. Support with relevant documents.
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Mention hospitals infrastructure facilities, special facilities, back-up support, it with documents.
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Complainant has not come to the court with clean hands i.e. he has suppressed material facts, e.g. previous illness, treatment etc.
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Inconsistence between notices sent directly or through consumer groups and the complaint made in the court.
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Written evidence of consent of the patient/relative/attendant to assumption of inherent and special risks in the treatment.
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Circumstances of the case; viz. There was emergency, lack of facilities (e.g. rural area) no one to give history of patient’s illness
etc.
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Burden of proof of:
(i) duty of care; (ii) breach of that duty; (iii) causation; (iv) damage, etc. is on the complainant.
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Reasonable knowledge, skill and care exercised (Rely/quote standard text books with attested photocopies).
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Consolation/treatment by patient from other doctor/other systems of medicine simultaneously.
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Many other reasons/more than on reason/for occurrence of damage.
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Contributory negligence.
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