VidhiSangh

Supreme Court of India · 12/05/2026

NARAYANA HEALTH & ORS. versus THE STATE OF WEST BENGAL & ORS.

[2026] 5 S.C.R. 584 · 2026 INSC 481

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Summary

A complaint against a hospital, its operating company, its Chairman and staff over a Rs. 2,500 charge for a test not performed (which the hospital offered to refund), delay in supplying medical records and alleged threats disclosed no criminal offence; billing and records grievances fall under the remedial scheme of the West Bengal Clinical Establishments Act, 2017. The complaint was quashed under Section 482 CrPC.

Issues

  1. Whether the allegations, taken at face value, disclosed criminal breach of trust, cheating or criminal conspiracy under the IPC.
  2. Whether the High Court was justified in observing that an offence under Section 504 IPC was made out when neither the complaint nor the summoning order invoked it.
  3. Whether a billing discrepancy and delay in supplying medical records constituted an offence under Section 34 of the West Bengal Clinical Establishments (Registration, Regulation and Transparency) Act, 2017.
  4. Whether the High Court should have quashed the complaint instead of remanding the matter to the Magistrate.

Provisions considered

Held

Result

Appeals allowed; the High Court judgment dated 16.05.2023 was set aside and Complaint Case No. C-533 of 2021 was quashed, leaving civil and statutory remedies open to the complainant.

Judgment PDF: Supreme Court of India, [2026] 5 S.C.R. 584.