Vasuhi v Tan Tock Seng Hospital: Negligence Claim for Death After Heart Attack

Madam Vasuhi d/o Ramasamypillai sued Tan Tock Seng Hospital Pte Ltd in the High Court of Singapore, alleging negligence in the treatment of her husband, Karunanithi s/o K Kalandavelu, who died of a heart attack on 16 August 1997. The plaintiff contended that the hospital's doctors failed to provide proper treatment, specifically by not performing a coronary angiogram before discharging him. Tan Lee Meng J dismissed the claim, finding no negligence on the part of the hospital's doctors.

1. Case Overview

1.1 Court

High Court

1.2 Outcome

Claim dismissed.

1.3 Case Type

Civil

1.4 Judgment Type

Grounds of Decision

1.5 Jurisdiction

Singapore

1.6 Description

A negligence claim against Tan Tock Seng Hospital for a patient's death from a heart attack. The court dismissed the claim, finding no negligence in the hospital's treatment.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
Tan Tock Seng Hospital Pte LtdDefendantCorporationClaim DismissedWon
Vasuhi d/o RamasamypillaiPlaintiffIndividualClaim DismissedLost

3. Judges

Judge NameTitleDelivered Judgment
Tan Lee MengJudgeYes

4. Counsels

Counsel NameOrganization
Christopher ChongHelen Yeo & Partners
Sharmila NairHelen Yeo & Partners
Seenivasan LalitaVirginia Quek Lalita & Partners

4. Facts

  1. The deceased had a long history of heart trouble, asthma, and systemic lupus erythematosus.
  2. The deceased suffered a heart attack in 1984.
  3. The deceased suffered a second heart attack on 1 August 1997 and was warded in Tan Tock Seng Hospital.
  4. An echocardiogram revealed that the deceased's left ventricular function was severely impaired.
  5. Dr. Alfred Cheng discharged the deceased on 8 August 1997, pending a further evaluation of his condition.
  6. A coronary angiogram was scheduled for late October 1997.
  7. The deceased suffered a fatal heart attack on 16 August 1997.

5. Formal Citations

  1. Vasuhi d/o Ramasamypillai v Tan Tock Seng Hospital Pte Ltd, Suit 517/2000, [2001] SGHC 30

6. Timeline

DateEvent
Deceased suffered a heart attack.
Deceased suffered a second heart attack and was warded in Tan Tock Seng Hospital.
Signal average ECG was done.
Echocardiogram was done.
Sub-maximal exercise stress test was done.
Deceased was discharged from Tan Tock Seng Hospital.
Deceased suffered a fatal heart attack.
Coronary angiogram was scheduled.
Suit filed (Suit 517/2000).
Decision Date

7. Legal Issues

  1. Negligence of Doctors
    • Outcome: The court found no negligence on the part of the doctors.
    • Category: Substantive
    • Sub-Issues:
      • Failure to administer thrombolytic therapy
      • Failure to recognize increased risk of heart attack
      • Failure to arrange for coronary angiogram prior to discharge
      • Failure to advise on urgency of coronary angiography
  2. Causation
    • Outcome: The court found that the deceased's death was not caused by any delay on the part of the hospital in arranging for the elective coronary angiogram.
    • Category: Substantive
    • Sub-Issues:
      • Whether death was caused by delay of coronary angiogram

8. Remedies Sought

  1. Monetary Damages

9. Cause of Actions

  • Negligence

10. Practice Areas

  • Personal Injury
  • Medical Malpractice

11. Industries

  • Healthcare

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
Bolam v Friern Hospital Management CommitteeN/AYes[1957] 2 All ER 118N/ACited as the locus classicus of the test for the standard of care required of a doctor.
Bolam v Friern Hospital Management CommitteeN/AYes[1957] 1 WLR 582N/ACited as the locus classicus of the test for the standard of care required of a doctor.
Hucks v ColeEnglish Court of AppealYes[1993] 4 Med LR 393EnglandCited to illustrate that a court must examine a lacuna in professional practice where risks of grave danger are knowingly taken.
Edward Wong Finance Co v Johnson Stokes & MasterPrivy CouncilYes[1984] AC 1296N/ACited regarding scrutiny of the Bolam test.
Rogers v WhitakerHigh Court of AustraliaYes[1992] 175 CLR 479AustraliaCited regarding scrutiny of the Bolam test.
Bolitho v City and Hackney Health AuthorityHouse of LordsYes[1998] AC 232N/ACited for the principle that the court must be satisfied that the exponents of a body of medical opinion can demonstrate that such opinion has a logical basis.
Bolitho v City and Hackney Health AuthorityHouse of LordsYes[1997] 4 All ER 771N/ACited for the principle that the court must be satisfied that the exponents of a body of medical opinion can demonstrate that such opinion has a logical basis.
Maynard v West Midlands Regional Health AuthorityN/AYes[1985] 1 All ER 635N/ACited for the principle that a doctor is not negligent merely because their conclusion differs from that of other professional men.
Maynard v West Midlands Regional Health AuthorityN/AYes[1984] 1 WLR 634N/ACited for the principle that a doctor is not negligent merely because their conclusion differs from that of other professional men.
Hunter v HanleyN/AYes1955 SLT 213N/ACited for the principle that a doctor is not negligent merely because their conclusion differs from that of other professional men.
Bolitho v City and Hackney Health AuthorityCourt of AppealYes[1994] 1 Med LR 381N/ACited regarding causation.

13. Applicable Rules

Rule Name
No applicable rules

14. Applicable Statutes

Statute NameJurisdiction
No applicable statutes

15. Key Terms and Keywords

15.1 Key Terms

  • Coronary angiogram
  • Thrombolytic therapy
  • Echocardiogram
  • Sub-maximal exercise stress test
  • Ischaemia
  • Ejection fraction
  • Bolam test
  • Elective coronary angiogram
  • Urgent coronary angiogram

15.2 Keywords

  • Negligence
  • Heart attack
  • Coronary angiogram
  • Medical negligence
  • Hospital
  • Doctors
  • Singapore

17. Areas of Law

Area NameRelevance Score
Medical Negligence95
Medical Malpractice90
Breach of Duty of Care80
Personal Injury60
Cardiology50

16. Subjects

  • Medical Law
  • Negligence
  • Tort Law