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(a)   Establish a clear airway by removing the secretions, if any, from the oropharynx.

This was already done by this opposite party by way of putting airway as stated earlier.

(b)   Oxygenate the patient with 100% oxygen.

Administration of oxygen was already on in this case.

(c ) Give external cardiac massage.

This was done by the opposite party No. 3 by thumping the chest once followed by pumping the same with palms of both the hands placed one over the other and pressing and releasing the patients chest wall at the rate of about 80 times per minute.

(d)   Simultaneously ventilate the patients lungs with 100% oxygen at the rate of about 20 bursts per minute that is one burst of oxygen after every fourth pump on the chest wall. This ventilation was done by this opposite party by pressing the reservoir bag of the anaesthesia machine.

(e)   Administration of Adrenaline. As per the standard practice of C P R procedure Adrenaline is administered only after the heart has failed to respond to the external cardiac massage. If Adrenaline is administered prematurely, that is during bradycardia, it will precipitate the cardiac arrest by itself. Therefore, Adrenaline is administered after the C P R is tried for some time and the patient fails to respond.

Written submissions of OP No.3 Dr Chandavarkar :

It is an admitted fact that surgery on the deceased had not yet commenced when she expired. It is again an admitted fact that not one incision had been made by OP

3 upon the deceased when the death occurred. The opposite party did all that was best possible to revive and resuscitate the deceased under the supervision of OP No. 2., when OP No. 2 informed that the deceased was showing signs of Bradycardia.

Massage was given by OP No. 3 continuously under the supervision of OP No. 2 in an attempt to save the deceased. Just as no anaesthetist can direct or control any surgery performed by the Gynaecologist, similarly no Gynaecologist can control or direct the methods or the means or medicine in the administration of anaesthesia to any patient. In fact OP No. 3s responsibility would have commenced only upon the first incision having being made on the patient signifying the commencement of the surgery which in this case was not done. A provisional diagnosis of dysfunctional uterine bleeding/ Adenomyosis was made. After the treatment, bleeding had stopped, she had a mild pain in the back and abdomen. She also desired to get the hysterectomy done in the near future.

DATE TIME   NURSES SIGN 1.40 P.M. Received the Patient in O.T. at 1.40 p.m.     Catheterisation done at 2 pm Cardiac     Monitoring done. Pt is conscious B.P.-120/80 mm Hg     Pulse 88/min. After scolin there was     difficulty in passing endotracheal tube     O2 under pressure given     Inj Atropine 1 amp given. Patient gone to     Bradycardia. Inj Efcorlin 200 mg i.v.given     Inj mephentin c.c. I.V. given Inj Adrenaline     amp Intracardial given. Cardiac massage     given. External cardiac shock given (160) Signature   Inj Adrenaline 1 ampoule i.v. & Inj Atropin     amp I.V given. Cardiac Massage     given by Dr. Chandavarker,     Dr Ravi Rupwate & Dr. Harish Signature   alternatively. All life saving Signature   measures failed and declared     Death at 3 p.m. Informed to Signature   Vartak Nagar police station. Reply     received & attached the file.