Judicial Restraint Paramount For Cognizance In Medico-Legal Cases: Rajasthan HC Exonerates Doctors Charged Of Forging Pathological Report

In medico-legal matters, where the stakes often involve not just reputations but also public trust in healthcare systems, the consequences of presumptive reasoning are magnified. Justice Farjand Ali opined that the risk of invoking presumptions under Section 114, Indian Evidence Act in medico-legal matters was magnified and hence in such cases, the Court must refrain from applying the theory of general presumptions unless there was clear, scientific and legally admissible evidence available to substantiate the allegations. The Jodhpur bench of the Rajasthan High Court has underscored that in cases concerning doctors/hospital administration involving allegations of forging pathological reports, meticulous judicial scrutiny was required before taking cognizance, especially when the doctor had not refuted the authenticity of the signatures. Even if there were differences in the style or appearance of the signatures, such inconsistencies absent conclusive proof of falsification cannot suffice to render the reports forged or fabricated…Thus, the pathological reports, rooted in advanced scientific techniques and professional oversight, cannot be dismissed on the basis of alleged signature discrepancies” Furthermore, the Court analysed the charges in light of the ingredients of the specific sections under IPC and observed that existence of a “false document” was a prerequisite for invoking the charge of forgery. Consequently, it is incumbent upon the judiciary to exercise heightened scrutiny and circumspection before attributing criminal culpability under the aforementioned sections.” In this background, the Court opined that even though at the stage of cognizance, comprehensive examination was not needed, in cases where criminal complaint was against the doctors and healthcare institutions, the degree of examination had to be on a higher pedestal where such allegations could be afterthought based on resentment due to unfavourable human expectation.