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Supreme Court of India 2023-09-05 dismissed

Prakash Bang vs Glaxo Smithkline Pharmaceuticals Ltd. & Anr

Bench: 2 — A.S. Bopanna, Prashant Kumar Mishra

In Brief

The appellant claimed that the Engerix-B vaccine caused myositis (muscle inflammation) in his shoulder, seeking compensation from the manufacturer Glaxo Smithkline Pharmaceuticals. While his family members who received the same vaccine batch experienced no adverse effects, he suffered shoulder pain four days after vaccination. The Supreme Court dismissed his appeal, holding that he failed to establish causation between the vaccine and myositis through adequate medical evidence. The affidavits filed lacked supporting medical records or authenticated material. The Court found that manufacturers need not list minimal adverse reactions (0.02 per million doses) if causation is difficult to establish, and the appellant's refusal to provide a muscle biopsy despite the manufacturer's request was held against him.

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Consumer Protection Medical Negligence Deficiency of Service Pharmaceutical Liability Product Liability Vaccine Adverse Reactions Burden of Proof Evidence

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