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A.S. Mittal v. State of U.P. (Confirm Rule)

31 October, 2025
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A.S. Mittal v. State of U.P. (1989) — Eye Camp Negligence & Confirm Rule | The Law Easy

A.S. Mittal v. State of U.P. (Confirm Rule)

Public Law · Medical Negligence 1989 3 SCC 223 1989 (decision), Published: 31 Oct 2025 Supreme Court of India Gulzar Hashmi ~6 min read
PRIMARY_KEYWORDS: eye camp negligence, sterile standards, PIL, confirm rule SECONDARY_KEYWORDS: causation, humanitarian relief, public health, cataract
Illustration of an eye surgery setup highlighting sterile standards

Quick Summary

A mass eye-camp at Khurja led to severe post-operative infections in many patients. A PIL sought compensation and accountability. The Supreme Court emphasized that sterile and aseptic standards must be actually maintained in such camps—real practice matters, not just paper guidelines. Causation was not finally proved, yet the Court granted humanitarian relief to victims.

Citation: A.S. Mittal v. State of U.P., 1989 3 SCC 223

Issues

  • Did the State ensure sufficient care and effective guidelines for eye-camps serving poorer patients?

Rules

The highest standards of aseptic and sterile conditions are essential wherever ophthalmic (or any) surgery is performed.
Outcomes depend on professional commitment in implementation, not on theoretical standards alone.

Facts (Timeline)

Timeline for A.S. Mittal case: eye camp, surgeries, infections, PIL
Lions Club, Pottery Town (Khurja, U.P.) held an eye-camp as social service.
Dr. R.M. Sahay and team were invited; publicity promised easy recovery and “no restrictions”.
On 21 April, about 122 examined; 108 operated (88 cataract). Doctor left the same evening for another camp at Moradabad.
Many Khurja patients developed post-op infections; eyes suffered serious damage despite antibiotics.
A similar, smaller mishap occurred at Moradabad (~15 affected).
Tracing suggested a common source: contaminated normal saline used during surgery.
PIL filed by A.S. Mittal and O.P. Tapas seeking damages and systemic measures.

Arguments

Petitioners (PIL)

  • Eye-camps targeted vulnerable patients; strict sterile control and oversight were mandatory.
  • State had a duty to frame and enforce workable guidelines and supervision.
  • Compensation/rehabilitation needed for those who lost vision.

Respondents (State/Organizers)

  • Standards existed; teams were qualified.
  • Causation was uncertain; infection source needed conclusive proof.

Judgment

Gavel and medical cross symbolising the judgment and relief

The Supreme Court of India stressed that mass surgical camps must operate at the highest aseptic standards. Though proximate causation was not conclusively proved, the Court ordered humanitarian monetary relief to victims: initially Rs. 5,000, plus an additional Rs. 12,500 each.

Real-world sterile practice—not theory—decides safety in surgical camps.

Ratio

Public health or charity camps performing surgery must maintain strict asepsis at every stage—facility, instruments, fluids, staff discipline, and follow-up. Paper rules are insufficient unless implemented with professional commitment. Courts may grant immediate relief to protect affected patients even while causation is being proved.

Why It Matters

  • Protects low-income patients who rely on outreach surgery.
  • Pushes States to issue and enforce practical SOPs for camps.
  • Shows how PIL can secure quick relief alongside systemic directions.

Key Takeaways

  1. Sterility is non-negotiable in mass surgery camps.
  2. Guidelines must be implemented, audited, and supervised.
  3. Causation issues may delay fault findings, but relief can still be granted.
  4. Publicity must not downplay risks or after-care.

Mnemonic + 3-Step Hook

Mnemonic: “CAMP = CLEAN, ACT, MONITOR, PROTECT.”

  • Clean: Fluids, instruments, venue must be sterile.
  • Act: Follow SOPs in real time, not on paper.
  • Monitor & Protect: Supervise and give prompt after-care/relief.

IRAC Outline

Issue

Did the State ensure effective, implemented aseptic standards for eye-camps serving the poor?

Rule

Maintain the highest sterile standards; outcomes depend on committed implementation, not mere theory.

Application

Contaminated saline indicated a systemic lapse. Messaging minimized after-care; oversight appeared weak during mass operations.

Conclusion

Court reinforced the standard and granted humanitarian relief while causation remained under scrutiny.

Glossary

Asepsis
Keeping procedures and environments free from pathogenic microorganisms.
PIL (Public Interest Litigation)
A petition to protect public rights or vulnerable groups, even by persons not directly injured.
Proximate Cause
A legally sufficient causal link between the act and the injury.

FAQs

No final strict liability finding. The Court focused on standards and gave relief pending conclusive causation proof.

They risked misleading patients about recovery and after-care, showing the need for responsible communication.

Robust SOPs, quality-controlled supplies (like saline), trained teams, supervision, and post-op follow-up at camps.

No. It is interim assistance and does not stop parties from proving or contesting liability later.
CASE_TITLE: A.S. Mittal v. State of U.P.  |  PUBLISH_DATE: 31 Oct 2025  |  AUTHOR_NAME: Gulzar Hashmi  |  LOCATION: India
Confirm Rule Medical Negligence Public Interest Litigation
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slug: as-mittal-v-state-of-up-confirm-rule PRIMARY_KEYWORDS: eye camp negligence, sterile standards, PIL, confirm rule SECONDARY_KEYWORDS: causation, humanitarian relief, public health, cataract
Timeline image for A.S. Mittal showing camp setup, surgeries, infections, PIL
Judgment image for A.S. Mittal with gavel and eye-care icon

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