Pappa v National University Health Services: Negligence & Duty of Care in Hospital Fall

Mdm Pappa w/o Veeramuthu, the Appellant, appealed to the General Division of the High Court against the decision of the District Court, which dismissed her claim against the Respondent, National University Health Services Group Pte Ltd, for negligence. Mdm Pappa sustained a fracture while recovering from surgery at Jurong Community Hospital. Hri Kumar Nair J allowed the appeal, finding that the hospital breached its duty of care by failing to ensure Mdm Pappa's safety and failing to ensure the call bell was within her reach.

1. Case Overview

1.1 Court

General Division of the High Court

1.2 Outcome

Appeal Allowed

1.3 Case Type

Civil

1.4 Judgment Type

Judgment

1.5 Jurisdiction

Singapore

1.6 Description

Mdm Pappa, recovering from surgery, fell in Jurong Community Hospital. The court found the hospital negligent for failing to ensure her safety.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
Pappa w/o VeeramuthuAppellantIndividualAppeal AllowedWon
National University Health Services Group Pte LtdRespondentCorporationAppeal DismissedLost

3. Judges

Judge NameTitleDelivered Judgment
Hri Kumar NairJudgeYes

4. Counsels

Counsel NameOrganization
Ranita YogeeswaranK&L Gates Straits Law LLC
Palaniappan SundararajK&L Gates Straits Law LLC
Vanessa YongLegal Clinic LLC
Melissa ErLegal Clinic LLC

4. Facts

  1. Mdm Pappa, 80 years old, was recovering from surgery on her broken right leg at Jurong Community Hospital.
  2. She fell and fractured her other leg while in the hospital.
  3. Mdm Pappa was assessed as a patient at risk of falling throughout her stay.
  4. She was placed in a single-bed isolation room with limited visibility from the nursing staff.
  5. The call bell was her only means of communicating with the nursing staff.
  6. Mdm Pappa was found seated in a visitor's chair before the fall.
  7. She experienced back pain and attempted to move to the bed on her own, resulting in the fall.

5. Formal Citations

  1. Pappa w/o Veeramuthu v National University Health Services Group Pte Ltd, District Court Appeal No 39 of 2022, [2023] SGHC 70

6. Timeline

DateEvent
Mdm Pappa admitted to Ng Teng Fong General Hospital
Mdm Pappa underwent right hip fixation surgery
Mdm Pappa transferred to Jurong Community Hospital
Mdm Pappa developed an infection and was transferred to a single-bed isolation ward
Mdm Pappa fell and fractured her other leg
Mdm Pappa underwent surgery on her left femur
Mdm Pappa transferred to St Luke’s Hospital for rehabilitation
Trial began in DC/DC 890/2020
Judgment reserved
Judgment issued

7. Legal Issues

  1. Breach of Duty of Care
    • Outcome: The court found that the respondent breached its duty of care to the appellant.
    • Category: Substantive
    • Sub-Issues:
      • Failure to provide reasonable medical and/or nursing care
      • Failure to ensure proper supervision and/or monitoring
      • Failure to ensure the call bell was within reach
  2. Negligence
    • Outcome: The court found the respondent negligent.
    • Category: Substantive
    • Sub-Issues:
      • Causation
      • Standard of care

8. Remedies Sought

  1. Monetary Damages

9. Cause of Actions

  • Negligence
  • Breach of Contract

10. Practice Areas

  • Personal Injury
  • Medical Malpractice
  • Civil Litigation

11. Industries

  • Healthcare

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
Re A (Relocation)EWHCYes[2020] EWHC 2878 (Fam)England and WalesCited for the principle that a contemporaneous account of a witness which corroborates their testimony at trial makes their evidence more credible.

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

  • Negligence
  • Duty of Care
  • Fall Risk
  • Isolation Room
  • Call Bell
  • Standard of Care
  • Self-ambulation
  • Contributory Negligence

15.2 Keywords

  • Negligence
  • Hospital
  • Fall
  • Duty of Care
  • Patient Safety

17. Areas of Law

Area NameRelevance Score
Negligence90
Breach of Duty of Care90
Personal Injury70
Torts60
Measure of Damages30
Contract Law20

16. Subjects

  • Medical Negligence
  • Hospital Liability
  • Duty of Care