Chia Soo Kiang v Tan Tock Seng Hospital: Medical Negligence & Informed Consent
In Chia Soo Kiang (personal representative of the estate of Tan Yaw Lan, deceased) v Tan Tock Seng Hospital Pte Ltd and others, the High Court of Singapore dismissed the plaintiff's claim of medical negligence against Tan Tock Seng Hospital and several doctors. The plaintiff alleged negligence in diagnosing the deceased's condition, administering treatment, and failing to obtain informed consent regarding medication changes. The court found no evidence of negligence, accepting the defense's argument that the deceased received appropriate care for her condition. The action was dismissed with costs.
1. Case Overview
1.1 Court
General Division of the High Court1.2 Outcome
Action dismissed with costs.
1.3 Case Type
Civil
1.4 Judgment Type
Judgment
1.5 Jurisdiction
Singapore
1.6 Description
Medical negligence case involving alleged misdiagnosis and failure to obtain informed consent. The court dismissed the action, finding no negligence.
1.7 Decision Date
2. Parties and Outcomes
| Party Name | Role | Type | Outcome | Outcome Type | Counsels |
|---|---|---|---|---|---|
| Chia Soo Kiang | Plaintiff | Individual | Action dismissed | Lost | Clarence Lun Yaodong, Cheston Ow, Renesh Boss |
| Tan Tock Seng Hospital Pte Ltd | Defendant | Corporation | Judgment for Defendant | Won | Mar Seow Hwei, Lee Qiu Li, Lydia Yeow Ye Xi |
| Dr Dorai Raj D. Appadorai | Defendant | Individual | Judgment for Defendant | Won | Mar Seow Hwei, Lee Qiu Li, Lydia Yeow Ye Xi |
| Dr Lee Wei Sheng | Defendant | Individual | Judgment for Defendant | Won | Mar Seow Hwei, Lee Qiu Li, Lydia Yeow Ye Xi |
| Dr Ranjana Acharya | Defendant | Individual | Judgment for Defendant | Won | Mar Seow Hwei, Lee Qiu Li, Lydia Yeow Ye Xi |
3. Judges
| Judge Name | Title | Delivered Judgment |
|---|---|---|
| Choo Han Teck | Judge of the High Court | Yes |
4. Counsels
| Counsel Name | Organization |
|---|---|
| Clarence Lun Yaodong | Fervent Chambers LLC |
| Cheston Ow | Fervent Chambers LLC |
| Renesh Boss | Fervent Chambers LLC |
| Mar Seow Hwei | Dentons Rodyk & Davidson LLP |
| Lee Qiu Li | Dentons Rodyk & Davidson LLP |
| Lydia Yeow Ye Xi | Dentons Rodyk & Davidson LLP |
4. Facts
- Madam Tan Yaw Lan, 74, had multiple ailments including ischaemic heart disease and type 2 diabetes.
- She was admitted to TTSH on 18 January 2018 for an acute myocardial injury and discharged on 23 January 2018.
- She returned to TTSH on 20 April 2018 with a persistent fever and was diagnosed with sepsis.
- Doctors initially diagnosed her with sepsis complicated by type 2 myocardial infarction.
- Her medications, including aspirin, losartan, and Lasix, were temporarily stopped.
- On 23 April 2018, she collapsed in the shower and passed away three weeks later on 13 May 2018.
- An autopsy was not performed at the family's request.
5. Formal Citations
- Chia Soo Kiang (personal representative of the estate of Tan Yaw Lan, deceased) v Tan Tock Seng Hospital Pte Ltd and others, Suit No 554 of 2019, [2022] SGHC 259
6. Timeline
| Date | Event |
|---|---|
| Madam Tan Yaw Lan admitted to Tan Tock Seng Hospital for an acute myocardial injury. | |
| Madam Tan Yaw Lan discharged from Tan Tock Seng Hospital. | |
| Madam Tan Yaw Lan returned to Tan Tock Seng Hospital by ambulance. | |
| Madam Tan Yaw Lan collapsed in the shower. | |
| Madam Tan Yaw Lan passed away. | |
| Suit filed in the General Division of the High Court. | |
| Trial commenced. | |
| Trial concluded. | |
| Judgment reserved. |
7. Legal Issues
- Medical Negligence
- Outcome: The court found no negligence on the part of the defendants.
- Category: Substantive
- Sub-Issues:
- Failure to diagnose type 1 myocardial infarction
- Negligence in taking patient for shower
- Delay in resuscitation efforts
- Informed Consent
- Outcome: The court held that cessation of medication is a clinical decision and does not require patient consent.
- Category: Substantive
- Sub-Issues:
- Failure to obtain consent for stopping medication
8. Remedies Sought
- Damages for Negligence
- Compensation for Breach of Duty of Care
9. Cause of Actions
- Negligence
- Breach of Duty of Care
- Failure to Obtain Informed Consent
10. Practice Areas
- Medical Malpractice
- Civil Litigation
11. Industries
- Healthcare
12. Cited Cases
| Case Name | Court | Affirmed | Citation | Jurisdiction | Significance |
|---|---|---|---|---|---|
| No cited cases | |||||
13. Applicable Rules
| Rule Name |
|---|
| No applicable rules |
14. Applicable Statutes
| Statute Name | Jurisdiction |
|---|---|
| Civil Law Act (Cap 43, 1999 Rev Ed) | Singapore |
15. Key Terms and Keywords
15.1 Key Terms
- Medical Negligence
- Informed Consent
- Type 1 Myocardial Infarction
- Type 2 Myocardial Infarction
- Sepsis
- Cardiac Arrest
- Resuscitation
- Ischaemic Heart Disease
- Emergency Department
- Medication Withdrawal
15.2 Keywords
- medical negligence
- informed consent
- misdiagnosis
- sepsis
- cardiac arrest
- Tan Tock Seng Hospital
16. Subjects
- Medical Law
- Negligence
- Healthcare
17. Areas of Law
- Tort
- Negligence
- Medical Negligence
- Informed Consent