Kyofuna Jaridah v Kibuli Muslim Hospital and Another (Civil Suit No. 319 of 2019)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The High Court found the defendants jointly and severally liable for medical negligence following the death of the plaintiff's newborn infant. The Court held that the hospital and doctor breached their duty of care through delayed medical review, failure to secure timely specialist assessment, inadequate investigation, and deficiencies in the conduct of an emergency blood transfusion. Although the transfusion itself was not proved to be the immediate cause of death, the cumulative failures materially contributed to the infant's fatal deterioration. The hospital was held vicariously liable for its staff's negligence.
Outcome
Judgment entered for the plaintiff against the defendants jointly and severally for medical negligence, with awards of special damages, general damages, damages for loss of expectation of life, interest and costs
Facts
The plaintiff attended antenatal care at the first defendant hospital and was delivered by caesarean section on 5 October 2018. Her baby developed respiratory distress on 6 October 2018 but was not medically reviewed until 7 October 2018. The baby was diagnosed with haemorrhagic disease of the newborn and found to be anaemic and thrombocytopenic. When compatible donor blood could not be obtained, an emergency direct transfusion of the mother's blood into the baby was carried out on the advice of a consultant. The baby's condition deteriorated after the transfusion and he died on 9 October 2018. The Court directed the Uganda Medical and Dental Practitioners' Council to investigate, which found an eight-hour delay in medical review, absence of physical specialist assessment, inadequate investigation, and deficiencies in the transfusion procedure including absence of documented compatibility testing, proper equipment, and informed consent.
Issues
- Whether the defendants owed the plaintiff and her baby a duty of care.
- Whether the defendants breached the applicable standard of medical care in the treatment and management of Baby Jibreal Jumah Sewankambo.
- Whether any breach of duty caused or materially contributed to the death of the baby.
- Whether the first defendant is vicariously liable for the acts or omissions of the second defendant and the hospital staff.
- Whether the plaintiff is entitled to the reliefs sought, and if so, to what extent.
Orders
- It is declared that the defendants breached the duty of care owed to Baby Jibreal Jumah Sewankambo during his admission and treatment at Kibuli Muslim Hospital.
- It is declared that the negligent acts and omissions of the defendants materially contributed to the death of the deceased child.
- The first defendant is held vicariously liable for the negligent acts and omissions of its medical personnel, including the second defendant.
- The plaintiff is awarded special damages of UGX 17,368,600/=.
- The plaintiff is awarded general damages of UGX 100,000,000/=.
- The plaintiff is awarded UGX 30,000,000/= for loss of expectation of life.
- The claim for exemplary and punitive damages is dismissed.
- Interest at 8% per annum on special damages from the date of filing the suit until payment in full.
- Interest at 6% per annum on general damages from the date of this judgment until payment in full.
- Costs of the suit awarded to the plaintiff.
Rules and key headnotes
Cases cited (8)
- Blyth v Birmingham Waterworks Co. (1856) 11 Ex 781
- Sarah Watsemwa Goseltine & Another v Attorney General (High Court Civil Suit No. 675 of 2006)
- Muwonge v Attorney General [1967] EA 17
- Avi Enterprises Ltd v Orient Bank Limited & Another (High Court Civil Suit No. 147 of 2012)
- Emma Gabriel (suing through Aulo Emma, mother and next friend) v Doctor's Hospital Sseguku Limited (Civil Appeal No. 004 of 2022)
- Jani Properties Ltd v Dar es Salaam City Council [1966] EA 281
- Watsemwa & Another v Attorney General [2015] UGHCCD 16
- Hirani Manji Kanji v Uganda Funeral Services Limited (High Court Civil Suit No. 115 of 2022)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.