‘No Medical Negligence If Hair Regrowth Fails’: NCDRC Relieves LifeCell, Doctors In PRP Treatment Case

Mumbai, May 22: The National Consumer Disputes Redressal Commission (NCDRC) has set aside orders passed by the Maharashtra consumer forums that had held LifeCell International Pvt. Ltd. and two doctors guilty of deficiency in service and unfair medical trade practice in a hair regrowth treatment dispute, ruling that no medical negligence was proved merely because the treatment failed to yield the desired results.

NCDRC overturns findings of negligence

The commission, in its order, held that there was “no foundation” to hold the doctors or the company guilty of unfair medical trade practice or negligence and observed that LifeCell appeared to have been impleaded only because it had referred the complainant to the doctors for treatment.

In a detailed order pronounced on April 23, 2026, the NCDRC allowed revision petitions filed by LifeCell International Pvt. Ltd., dermatologist Dr Madhuri Agarwal and plastic surgeon Dr Satish Kishoranand Arolkar, while dismissing the revision petitions filed by complainant Sushil Mukesh Gaglani.

The dispute arose after Gaglani, a Kandivali resident and advocate by profession, underwent three sessions of Platelet Rich Plasma (PRP) therapy in 2013 for hair regrowth after allegedly being assured of a “100% positive result” by representatives associated with LifeCell. He later alleged that the treatment caused tremendous pain and failed to produce any hair regrowth.

Complainant sought compensation

According to the complaint, Gaglani first came into contact with LifeCell during his wife’s pregnancy while exploring umbilical cord preservation services offered by the company.

During the process, he was informed about PRP hair regrowth therapy by company executive Chetan Purushottam. He alleged that he was assured that the procedure would produce positive hair regrowth results.

Relying on those representations, the complainant underwent three PRP sessions between July and August 2013 under the supervision of Dr Agarwal and Dr Arolkar at clinics in Mumbai.

However, after failing to notice any improvement, he accused the company and doctors of misleading him regarding the benefits of PRP treatment and filed a consumer complaint seeking compensation of over Rs 19 lakh.

The District Consumer Disputes Redressal Forum in Mumbai had in 2018 held all opposite parties jointly liable for unfair trade practice and deficiency in service and directed them to refund Rs 59,525 along with Rs 10 lakh compensation for mental harassment.

The Maharashtra State Consumer Disputes Redressal Commission later reduced the compensation to Rs 6 lakh but upheld the findings of negligence and unfair trade practice.

Commission cites lack of expert evidence

However, the NCDRC found that both lower forums had misunderstood the nature of PRP therapy and wrongly equated it with stem cell treatment.

The commission observed that PRP therapy for hair regrowth is a globally accepted procedure distinct from stem cell therapy and does not require separate approvals or licences under the Drugs and Cosmetics Act, as assumed by the lower forums. It noted that PRP treatment involves using a patient’s own blood plasma and that the outcome can vary from person to person.

Rejecting allegations of negligence, the NCDRC held that the complainant had failed to produce expert evidence to establish medical negligence or deficiency in service.

“The complainant in the present case happens to be a professional advocate and the complaint has been filed almost after two years of undertaking the treatment. No expert evidence has been led on record by the complainant to prove any negligence in rendering the PRP treatment,” the commission observed.

The NCDRC further held that merely because the expected results were not achieved, an adverse inference could not be drawn against the doctors or the company. It noted that the complainant had voluntarily undergone all three sessions after reviewing brochures, the company website and signing consent forms.

“There is no cogent evidence to assume that complainant had been misled by the doctors in any manner. The allegations cannot be deemed to be proved merely by making bald averments,” the commission said.

Supreme Court rulings cited

The commission also relied on several Supreme Court rulings relating to medical negligence, including Jacob Mathew v. State of Punjab and Malay Kumar Ganguly v. Sukumar Mukherjee, reiterating that a doctor cannot be held negligent merely because a treatment did not yield the desired outcome.

Quoting from the Supreme Court’s observations, the NCDRC said that medical practitioners should not be subjected to harassment unless a higher threshold of proof is met by the complainant to establish breach of duty and direct injury attributable to such breach.

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“In the totality of facts and circumstances, we are of the firm view that negligence and deficiency in administering the treatment on the part of OP-3 and 4 has not been proved on record,” the commission held while setting aside the earlier orders passed by the district and state consumer forums.

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