Pai Lily v Yeo Peng Hock Henry: Medical Negligence, Limitation Act, and Causation in Eye Infection Case

In Pai Lily v Yeo Peng Hock Henry, the High Court of Singapore heard a medical negligence claim by Pai Lily against Dr. Yeo Peng Hock Henry. Pai Lily alleged that Dr. Yeo failed to exercise due care and skill in treating her infection in December 1996, which led to the loss of her left eye. The court found that Dr. Yeo was negligent in not advising Pai Lily to seek immediate hospital treatment on December 23, 1996, and that this negligence caused her injury. The court allowed Pai Lily's claim, finding Dr. Yeo liable for damages to be assessed.

1. Case Overview

1.1 Court

High Court

1.2 Outcome

Claim allowed.

1.3 Case Type

Civil

1.4 Judgment Type

Grounds of Decision

1.5 Jurisdiction

Singapore

1.6 Description

Medical negligence claim against Dr. Yeo for failing to diagnose and advise immediate treatment for Pai Lily's eye infection, resulting in vision loss.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
Yeo Peng Hock HenryDefendantIndividualClaim AllowedLost
Pai LilyPlaintiffIndividualClaim AllowedWon

3. Judges

Judge NameTitleDelivered Judgment
Lee Seiu KinJudicial CommissionerYes

4. Counsels

Counsel NameOrganization
Maurice CheongDonaldson & Burkinshaw
David WeeDonaldson & Burkinshaw
Edmund KronenburgDrew & Napier
Kalyani RajendranDrew & Napier

4. Facts

  1. Pai Lily consulted Dr. Yeo for general medical problems since February 1992.
  2. Pai Lily consulted Dr. Yeo three times in December 1996 for an infection.
  3. On December 23, 1996, Pai Lily complained of fever, knee pain, and a film over her left eye.
  4. Dr. Yeo suspected a detached retina but did not advise Pai Lily to go to the hospital immediately.
  5. Pai Lily's condition worsened, leading to the loss of her left eye.
  6. Dr. Ang, an eye specialist, testified that Pai Lily's eye would probably have been saved if she had gone to the hospital on December 23, 1996.
  7. The court found that Dr. Yeo did not advise Pai Lily to go to the hospital immediately on December 23, 1996.

5. Formal Citations

  1. Pai Lily v Yeo Peng Hock Henry, Suit 600030/2000, [2001] SGHC 58

6. Timeline

DateEvent
Yeo Peng Hock Henry graduated from the University of Singapore with an MBBS.
Yeo Peng Hock Henry started general practice.
Pai Lily began consulting Yeo Peng Hock Henry for general medical problems.
Pai Lily consulted Yeo Peng Hock Henry for fever, backache, and giddiness.
Pai Lily consulted Yeo Peng Hock Henry again, still experiencing fever, backache, and giddiness.
Pai Lily consulted Dr. Teng Shi Chong at Bedok Family Clinic due to worsening condition.
Pai Lily consulted Yeo Peng Hock Henry, complaining of fever, knee pain, and a film over her left eye.
Pai Lily was warded at Singapore General Hospital.
Scheduled date for blood and urine tests at Bedok Polyclinic if Pai Lily was not admitted to hospital.
Pai Lily was discharged from Singapore General Hospital.
Prof Stuart Brown concluded there was nothing improper about Pai Lily's treatment by SNEC and SGH.
Prof Stuart Brown advised Pai Lily that Yeo Peng Hock Henry's treatment was unacceptable.
Writ filed by Pai Lily against Yeo Peng Hock Henry.
Decision date of the High Court.

7. Legal Issues

  1. Medical Negligence
    • Outcome: The court found the defendant negligent in failing to advise the plaintiff to seek immediate hospital treatment.
    • Category: Substantive
    • Sub-Issues:
      • Failure to conduct test for urinary tract infection
      • Failure to stress urgency of seeking treatment at hospital's Accident and Emergency department
      • Causation of damage suffered by plaintiff
    • Related Cases:
      • [1957] 2 All ER 118
      • [1997] 4 All ER 771
  2. Limitation of Actions
    • Outcome: The court held that the plaintiff's claim was made within the three-year limitation period.
    • Category: Procedural
  3. Causation
    • Outcome: The court found that the defendant's negligence caused the damage suffered by the plaintiff.
    • Category: Substantive
    • Related Cases:
      • [1972] 3 All ER 1008
      • [1988] 1 All ER 871

8. Remedies Sought

  1. Monetary Damages

9. Cause of Actions

  • Medical Negligence
  • Breach of Contract

10. Practice Areas

  • Medical Malpractice
  • Civil Litigation

11. Industries

  • Healthcare

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
Bolam v Friern Hospital Management CommitteeQueen's Bench DivisionYes[1957] 2 All ER 118England and WalesCited for the Bolam test, which is the standard for determining medical negligence.
McGhee v National Coal BoardHouse of LordsYes[1972] 3 All ER 1008England and WalesCited for the principle that a person who substantially increases another person's risk of injury through negligence has thereby materially contributed to the victim's injury.
Wilsher v Essex Area Health AuthorityHouse of LordsYes[1988] 1 All ER 871England and WalesCited to qualify the principle in McGhee v National Coal Board, emphasizing that the burden of proving causation lies on the plaintiff.
Bolitho v City and Hackney Health AuthorityHouse of LordsYes[1997] 4 All ER 771England and WalesCited to modify the Bolam test, stating that a judge can reject expert opinion if it is not logically supported.

13. Applicable Rules

Rule Name
No applicable rules

14. Applicable Statutes

Statute NameJurisdiction
Limitation Act (Cap 163, 1996 Ed)Singapore

15. Key Terms and Keywords

15.1 Key Terms

  • Medical negligence
  • Urinary tract infection
  • Detached retina
  • Eye infection
  • Causation
  • Limitation Act
  • Bolam test
  • Apo-sulfatrim
  • General practitioner
  • Standard of care

15.2 Keywords

  • Medical negligence
  • Eye infection
  • Limitation Act
  • Singapore
  • High Court
  • Pai Lily
  • Yeo Peng Hock Henry

17. Areas of Law

Area NameRelevance Score
Medical Negligence95
Personal Injury60
Limitation50
Translation Service Business10

16. Subjects

  • Medical Law
  • Negligence
  • Civil Procedure