1. 1.Facts of the case.
1. Sealing of the health care establishments [clinic]
by Commission.
·
The Punjab health care commission which is established
to ban quackery and provide health care to individuals seal the clinic Of
mushtaq ahmed Chaudhry on the date of 4-9-2015
·
and all of those
practioner who are registered under unani act and hold the diploma from skill development
council on the ground of
I. 1.Quackery
II. 2.And not registered under Punjab health
commission act 2010
2. Challenge the sealing action of commission
by Medical practioner.
After the sealing of clinic the effected practioner challenge the action
of commission on ground that.
·
Commission has no legal authority to seal the
health care establishments of the medical practioner
3. Judgment passed against the Commission in
district court.
On the date of 20-11-2015 the
learned single judge of district court, toba tak Singh passed the judgment that
the action of the commission was without the any lawful authority.
·
Reason of
judgment
1.
The action of the commission was administrative
action which cannot be exercised/ enforceable against any third party.
2.
The commission has no rules and regulations
about of sealing so it’s not seem possible that this action exercised on delegated
legislation.
4. Appeal against the judgment by commission.
The commission challenges that
judgment in Supreme Court
5. Case refers to Lahore high court.
·
After appeal the case refer to High court
·
And now for hearing in front of High court for
the purpose of judgment
The one petition of the commission and in front of this the other two
petition of the
1.
Punjab dental practioner association
2.
Punjab dental practioner association and mushtaq
armed Chaudhary
And all these petition which has the same question of dispute like respondent against the commission.
2. Questions of dispute.
In front of High court all the petition which are filed
against the Commission the subject of all were same like they challenge the
1. 1.Vires/legal authority of PHCA 2010
2. 2.Challenge the sealing action of commission
3. 3.Provincial government not holds authority to
legislate on the subject of federal legislative list.
So
the court framed the two question of dispute to settle out the matter among the
parties.
1.
Vires of Health act
2.
Is the commission has authority to seal the
healthcare establishment under health act.
3. Arguments on questions
of dispute.
A-Argument on the 1st question
of dispute.
1. 1.From Respondent side
·
Mr. Muhammad Ahmed Quyum advocate on the side
of dental association and Mushtaq ahmed
chaudary challenge the vires of health act on the following grounds
1. The action of commission under health act
is ultra vires.
THE counsel argued that.
The action of commission is under provincial law and against those
practioner who are registered under unnai act [Federal law] and the services of
those practioner are related to the medical profession which is the subject of
federal legislative list means only federal govt has authority to legislate
about that’s matter while commission did that action under provincial authority
so commission act beyond his authority /ultravires
2. The action of commission under health act is unconstitutional
As the action of commission to seal clinic of the practioner of the
medical profession
And according to the Entry 11 ,part 2 of the FLL the medical ,legal and
all profession are the subject of FLL and here the commission under health act
attempt to legislate the medical profession so the act of commission is unconstitutional
3. The action of commission to seal health
care establishment is illegal.
The commission seals the
clinic of the practioner on the ground of
1. Quackery
2. Not
registered under health act
Which is illegal because the practioner are not quack they are qualified
and registered under unani act and having diploma from skill development
council
Moreover as their services are related to the medical profession and for
that they are already registered under unani act so they don’t need further
more registration under health act
4. The practioner registered under unani act
not need further registration under health act.
The services of the practioner related
to the medical profession and for that they are already registered under unani
act so they don’t need further more registration under health act
2. from commission side.
Khawaja Assam bin Harris advocate on the behalf of
commission favor the action of Commission under health act on the following grounds.
1. 1. The act of commission under health act is intravires.
The counsel argued that
The action of the commission to seal the
clinic of the practioner who are registered under unani act is for the sake of
health care services and health care services is the subject of PLL and fall under the object of health act
moreover that’s not fall under the scope of medical profession so ,the action
commission is intravires .
2. 2.The act of commission under health act is constitutional.
The constitutional
history of Pakistan also reveals that the subject of health care services is
always the subject of legislation of the PLL so the act of commission is
constitutional
3. 3. The action of seal is legal.
The health
act empower to ban quackery and improve health care services so all the
practioner and establishment which are not registered under health act the
commission has power to seal them and that is legal .
4. 4.Registration is required under health act.
Medical profession is just deal to the
qualification and the practioner that not deal with the health care establishment,
health care service and the service provider these all are the subject of the
health act so, if any tabb, doctor want to run clinic, hospital then its must
require the registration of that service provider and service provide
establishment under health act.
3. from Provincial Govt.
Mr. Anwar Husain additional advocate general argued that.
1.
Health care service is the subject of PLL.
The counsel argued that about of the health
care services the provincial govt has authority to legislate and that is proof
by constitutional history even tough if in the medical profession or in homeopath
has the business of providing health care service then the service provider
along with the establishment of service provider all fall in the Domain of PLL.
4. from Federal govt.
On behalf of federal govt Mr.Nasar Ahmed Deputy Attorney
General argued that.
1. 1.Health care services are the subject of
health act.
The object of the health act to improve
health care service and ban quackery so commission on the base of health act
has authority to take all necessary steps to accomplish that purpose.
2. 2. Registration under health act not the
violation of constitution
Counsel argued that as for the medical
practioner the federal govt require their registration under federal law in the
same way in related to the health care service the registration and likeness of
the service provider and the health care establishment is not the violation of
the constitution.
B-
2nd Question of Dispute
1. Against the action of the commission
about of seal to the health care establishment of the practitioner the counsel
argued that.
1. The commission can impose fine on the practioner but not hold the
authority to seal them.
2. The commission can take action only against
the quacks not the practioner
2. Reply from commission side
Ø In front of
the objection raised against the commission the commission counsel argued that.
Counsel argued that
the action of seal the clinic of practioner is legal and give following grounds
for that.
1. 1.The act of commission under health act.
The objective of the commission to ban quackery
and provide health care services and according to the health act
Every person is a quack who pretend to have
those skill of medical etc. which he not have and not registered under
PMDC,COUNCIL of tabb and council of homeopath and council of nursing
And as these all practitioner are not
registered under these relevant laws so fall under definition of quack so the
act of sealing is valid one not illegal.
Ø Reference.
1.
Section 4 of the health act
2.
The regulation/rule issued under sec 40[1] of
the health act in 2016
3.
The order of the Supreme Court which passed on
the date of 3-6-2018 where the power is given to commission to make sure the registration
and licensing of the healthcare establishment and service provider under the
health act.
2. 2.The action of seal is carried out according
to the rules of natural justice.
The counsel of the commission argued that
the action of the seal is carried out against the clinic of practioner after
following the principle of natural justice.
Audi alterum partum
‘’ Opportunity to being heard ‘’
Counsel argued that before to seal clinic
the notice is send to every practioner for the purpose that they come and show
their registration under health act but they consider that their registration
under unani act is enough and as commission has authority to take action to
secure health care services that’s why the action of seal is taken .
3. 3. The action of seal is for the safety of
public health.
Ø The counsel
argued that the objective of the commission to secure the public health and for
it the commission has authority to take all necessary action and that action of
sealing is also carried out under this perspective on the base of preventive
measure
Ø Because
the practioner are registered under unani act are not liable for their medical
negligence that negate that the health of public in risk because no one hold
the any liability in case of damage, loss etc. while the service provider
registered under health act are liable to his medical negligence .
Ø Counsel
argued that the action of commission is against quacks not practioner .
Reason.
Ø Counsel
argued that according to section 2[29] of health act
‘’A
quack is a person who pretends to provide health care service and not
registered under PMDC, council of Tabb, homeopathy and nursing ‘’
So ,the person whom against the commission
take action are also quack because to become practioner they need to be
registered under federal Law ,PMDC and to provide health care service they need
to be registered under health act as they are not registered under these laws
even registered under unani act so are not fall under definition of practioner
so the action of commission against them is valid .
4.objection
of the individual petitioner against the action of commission about of seal of
their clinic .
Ø Beside of
the Punjab medical dental association and Masha armed Chaudhary the other
respondent like Nagma Ashraf and zameer Ali shah raised objection of the
authority of Commission about of seal of their health care establishment on the
following grounds.
1. They have entitled to practice
dentistry and homeopath because of the many year practice.
2. They hold the diploma from the skill
development council
3. They are registered under uanni act.
In short their claim based on their Qualification.
Ø In contrast of the claim of the petitioner against
the action of commission on the base of their qualification the advocate
Chaudhary Muhammad Umar on behalf of commission argued that .
As the claim of the petitioner is based on
their qualification but counsel argued that the petitioner respective
qualification are not authorized under the national training ordinance
Ø Even the national training ordinance regulate
the training of the paramedical courses and the courses of the Allied health
profession include the dental technician and hygienist and after the training of the courses the
person are not entitled to practice without the supervision of the senior
dentist
Ø So here the practioner not hold the respective
degree to practice that respective profession moreover without training run
their separate clinic just on the qualification of diploma and registered under
umami act which are not enough to their respective services.
5. Judgment.
Ø Justice
Ayesha Malik decides the matter in favor of the health commission and approves
just the petition of the commission and dismisses the all other petition.
Ø Grounds
of judgment.
1. Constitutional history
By constitutional history of
Pakistan that is proof that the health care service is always the subject of
legislation of the PLL in all constitution of Pakistan 1956, 1962 and 1973 so,
only Provincial got has authority to legislate about that matter and medical
profession is the subject of the legislation of the FLL
2. The scope of health act
The health act deals with the health care establishment
,health care service provider and health care services so for anyone who want
to provide health care service and run health care establishment must need to
be registered and licenses by its own and its establishment under health act .
3. The scope of umami act-
The unani act deals with just
about the practioner and about of the qualification which require to enter in
that profession but not deals with health care services, establishment and
service provider.
4.
Commission
holds authority to ban quackery and secure health care.
The
commission has power to take all necessary steps to secure health care and ban
quackery.
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