The untimely death of Dr Ketan Bhatikar has understandably generated emotional discourse surrounding the availability of anti-snake venom in Goa. Yet, public law questions are rarely answered by emotion alone. The issue is not whether anti-snake venom exists somewhere within the territorial limits of the State. The more serious inquiry is whether a victim of neurotoxic envenomation can realistically survive the journey between the site of the bite and a medically functional treatment facility. That distinction matters.
A vial of anti-snake venom resting inside a government refrigerator does not by itself satisfy the constitutional obligation to preserve life. Neurotoxic envenomation does not merely demand pharmaceutical inventory. It requires a functioning chain of emergency response involving diagnosis, respiratory support, intubation capability, trained personnel, referral transport, and institutional coordination capable of operating within a rapidly narrowing window of survival. In many instances across India, mortality arises not from the absence of anti-snake venom itself, but from the collapse of the system surrounding it.
Protocol and preparedness
The Ministry of Health and Family Welfare has already recognised this distinction through the National Snakebite Management Protocol. The protocol does not contemplate symbolic compliance through passive storage of anti-snake venom alone. It envisages decentralised preparedness involving peripheral healthcare centres, early administration of anti-snake venom, ventilatory support, referral linkages, trained medical officers, and emergency stabilisation systems capable of functioning in rural and forest-linked regions.
That framework assumes particular significance in Goa. The State is no longer merely a coastal tourism destination. Its highways increasingly traverse ecologically sensitive forest corridors connecting human mobility with wildlife habitats. Monsoon displacement of reptiles, highway expansion, mining-linked transport corridors, tourism pressure, and increased vehicular penetration into forest belts have altered the nature of public risk. Snakebite management therefore cannot remain confined to tertiary hospitals alone. The question is no longer whether Goa possesses anti-snake venom stocks in the abstract. The question is whether the institutional chain contemplated by the National Snakebite Management Protocol can realistically preserve life in geographically vulnerable corridors such as Mollem, Dharbandora, Anmod, Sanguem, Valpoi, and similar regions adjoining dense forest terrain.
Ecology and highways
Modern highway governance cannot be divorced from ecological consequences. Forest corridors fragmented by transport infrastructure inevitably increase human interaction with displaced wildlife. Public administration readily recognises this principle while designing crash barriers, trauma ambulances, and emergency evacuation systems for accident-prone highways. Yet, toxicological emergencies remain largely absent from the conversation.
That omission is difficult to ignore. If highways are permitted to traverse ecologically sensitive snake habitats, then the corresponding duty to establish emergency toxicological response systems becomes equally foreseeable. The constitutional obligation under Article 21 of the Constitution cannot operate selectively depending upon whether death arises from a collision or envenomation. The “golden hour” principle recognised in emergency medical jurisprudence does not belong exclusively to road traffic accidents. Neurotoxic snakebite fatalities are equally dependent upon the speed of medical intervention.
Consequently, the absence of stabilisation facilities, ventilatory support, or trained toxicological response teams along vulnerable highway corridors may eventually invite scrutiny through the language of administrative negligence and constitutional accountability.
Beyond medical sympathy
The incident also revives an equally important but neglected dimension of criminal procedure. A snakebite fatality is not merely a medical occurrence. It is an evidentiary event. Under the Bharatiya Nagarik Suraksha Sanhita, 2023, sudden and unnatural deaths demand procedural seriousness through inquest and medico-legal investigation. The law does not permit the cause of death to be reduced into simplistic assumptions merely because a snakebite is alleged.
The investigative inquiry must therefore extend beyond the immediate bite itself. The chronology of treatment, referral delays, ambulance response, respiratory collapse, hospital preparedness, and post-mortem findings become equally relevant. Pulmonary oedema, cerebral complications, delayed paralysis, and toxic progression cannot be examined through conjecture alone. Scientific investigation remains indispensable not merely for determining the precise cause of death, but also for understanding whether systemic deficiencies aggravated the fatal outcome.
In ecologically vulnerable States such as Goa, snakebite deaths may increasingly require standardised medico-legal protocols capable of preserving epidemiological, forensic, and administrative evidence. Otherwise, institutional failures risk disappearing behind the convenient language of inevitability.
Constitutional distance:
The jurisprudence emerging from Paschim Banga Khet Mazdoor Samity v State of West Bengal (1989) and Parmanand Katara v Union of India (1996) has already established that preservation of life forms part of the constitutional duty of the State. However, constitutional language becomes meaningless if emergency infrastructure remains geographically disconnected from foreseeable zones of risk.
Goa’s public institutions need not wait for litigation to recognise this reality. The death of Dr Ketan Bhatikar deserves sympathy as a human tragedy. Yet, sympathy alone cannot become the final administrative response. The more difficult question concerns whether modern governance is willing to acknowledge that ecological risk corridors require corresponding medical preparedness, forensic seriousness, and institutional accountability. Without that recognition, anti-snake venom itself risks becoming little more than symbolic reassurance administered after the possibility of survival has already disappeared.
Necessity of judicial intervention
The jurisprudential challenge presented by snakebite fatalities in Goa therefore extends beyond medicine alone. A modern constitutional State cannot merely announce the availability of anti-snake venom while remaining institutionally indifferent to whether a victim can survive long enough to receive meaningful treatment.
Forest-linked highways, expanding ecological disruption, increased nocturnal mobility, and monsoon vulnerability have altered the nature of public risk within the State.
The response to such fatalities must consequently evolve beyond reactive sympathy and fragmented administrative assurances.
Scientific inquest under the Bharatiya Nagarik Suraksha Sanhita, 2023, functional emergency preparedness under the National Snakebite Management Protocol, and constitutional obligations flowing from Article 21 must operate together as part of a coherent framework of governance.
Otherwise, the distinction between preventable death and unavoidable tragedy risks becoming dangerously blurred within public administration itself.
