Yeo Peng Hock Henry v Pai Lily: Medical Negligence, Doctor's Duty of Care & Causation
In Yeo Peng Hock Henry v Pai Lily, the Court of Appeal of Singapore heard an appeal from Dr. Yeo Peng Hock Henry against Ms. Lily Pai, concerning a High Court decision holding Dr. Yeo liable for Ms. Pai's loss of vision due to medical negligence. The primary legal issue was whether Dr. Yeo's failure to advise Ms. Pai to seek immediate specialist attention for her eye condition on December 23, 1996, constituted a breach of his duty of care and whether this breach caused her loss of vision. The Court of Appeal allowed the appeal, finding that Ms. Pai failed to prove that Dr. Yeo's negligence caused or materially contributed to her loss of vision.
1. Case Overview
1.1 Court
Court of Appeal1.2 Outcome
Appeal Allowed
1.3 Case Type
Civil
1.4 Judgment Type
Grounds of Decision
1.5 Jurisdiction
Singapore
1.6 Description
Appeal regarding a doctor's negligence for not advising immediate specialist attention, leading to patient's vision loss. Court allowed the appeal, finding no causation.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Yeo Peng Hock Henry | Appellant | Individual | Appeal Allowed | Won | |
| Pai Lily | Respondent | Individual | Claim Dismissed | Lost |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Chao Hick Tin | Judge of Appeal | Yes |
| L P Thean | Judge of Appeal | No |
| Yong Pung How | Chief Justice | No |
4. Counsels
4. Facts
- Ms. Pai consulted Dr. Yeo on December 23, 1996, complaining of blurred vision in her left eye.
- Dr. Yeo suspected a detached retina but did not advise Ms. Pai to go immediately to the hospital or an eye specialist.
- Ms. Pai was later diagnosed with Endogenous Klebsiella Endophthalmitis (EKE), a rare eye infection.
- Ms. Pai lost vision in her left eye due to the EKE infection.
- Ms. Pai claimed Dr. Yeo's failure to advise immediate specialist attention led to delayed diagnosis and treatment.
- Dr. Yeo's expert testified that EKE is rare and difficult to diagnose early.
- The court found Ms. Pai did not prove that earlier treatment would have saved her eye.
5. Formal Citations
- Yeo Peng Hock Henry v Pai Lily, CA 600048/2001, [2001] SGCA 72
6. Timeline
| Date | Event |
|---|---|
| Dr. Yeo graduated from the University of Singapore with the degree of MBBS. | |
| Dr. Yeo became a clinical tutor for undergraduate medical students of the National University of Singapore. | |
| Ms. Pai began consulting Dr. Yeo for general medical problems. | |
| Ms. Pai consulted Dr. Yeo with complaints of fever, backache, and giddiness. | |
| Ms. Pai consulted Dr. Yeo again with similar complaints and an additional complaint of cough. | |
| Ms. Pai consulted Dr. Teng at Bedok Family Clinic and Surgery due to worsening symptoms. | |
| Ms. Pai consulted Dr. Yeo again, complaining of fever, chills, giddiness, pain over the right kneecap, and blurred vision in her left eye. | |
| Ms. Pai went to the Accident & Emergency Unit at 3.20 pm. | |
| Ms. Pai underwent a vitrectomy on her left eye. | |
| Ms. Pai lost the vision of her left eye. | |
| Court of Appeal decision. |
7. Legal Issues
- Medical Negligence
- Outcome: The court found that Dr. Yeo breached his duty of care by failing to advise Ms. Pai to seek immediate specialist attention.
- Category: Substantive
- Sub-Issues:
- Breach of duty of care
- Failure to advise immediate specialist attention
- Failure to diagnose
- Causation
- Outcome: The court found that Ms. Pai failed to prove that Dr. Yeo's negligence caused or materially contributed to her loss of vision.
- Category: Substantive
- Sub-Issues:
- Material contribution to injury
- Balance of probabilities
8. Remedies Sought
- Damages for Negligence
9. Cause of Actions
- Negligence
- Breach of Duty of Care
10. Practice Areas
- Personal Injury
- Medical Malpractice
- Litigation
11. Industries
- Healthcare
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| Bolam v Friern Hospital Committee | Unknown | Yes | [1957] 2 All ER 118 | England and Wales | Cited for the test to determine negligence or breach of duty by a doctor. |
| Bolitho v City & Hackney Health Authority | House of Lords | Yes | [1997] 3 WLR 1151 | England and Wales | Cited to supplement the Bolam test, stating that a judge could disregard a body of medical opinion if it could not be logically supported. |
| Bonnington Castings Ltd v Wardlaw | House of Lords | Yes | [1956] AC 613 | Scotland | Cited for the principle that a plaintiff must prove negligence or breach of duty caused or materially contributed to the injury. |
| Hotson v East Berkshire Area Health Authority | House of Lords | Yes | [1987] 2 All ER 909 | England and Wales | Cited to illustrate that the plaintiff must prove the injury was caused by the negligence of the hospital on a balance of probabilities. |
| Wilsher v Essex Area Health Authority | House of Lords | Yes | [1988] 1 All ER 871 | England and Wales | Cited to illustrate that the burden of proving causation lies with the plaintiff. |
| Hotson v East Berkshire Area Health Authority | House of Lords | Yes | [1987] 1 AC 750 | England and Wales | Cited to illustrate that the plaintiff must prove the injury was caused by the negligence of the hospital on a balance of probabilities. |
| Wilsher v Essex Area Health Authority | House of Lords | Yes | [1988] AC 1074 | England and Wales | Cited to illustrate that the burden of proving causation lies with the plaintiff. |
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| No applicable statutes | |
15. Key Terms and Keywords
15.1 Key Terms
- Medical negligence
- Duty of care
- Causation
- Endogenous Klebsiella Endophthalmitis
- Detached retina
- Standard of care
- Balance of probabilities
- Material contribution
- General practitioner
- Eye specialist
15.2 Keywords
- Medical negligence
- Duty of care
- Causation
- Eye infection
- Specialist
- Singapore
17. Areas of Law
| Area Name | Relevance Score |
|---|---|
| Medical Negligence | 95 |
| Breach of Duty of Care | 85 |
| Negligence | 80 |
| Causation | 75 |
| Personal Injury | 60 |
16. Subjects
- Medical Law
- Tort Law
- Negligence