A recent ruling by the Appellate Division of the Supreme Court of the State of New York has significant implications for a medical malpractice case involving Dr. Sadashiv S. Shenoy. The court's decision, issued on October 2, 2026, modifies a previous order regarding the scope of depositions in the case of Stang v. Shenoy, docket number 609 CA 25-01010. This ruling allows the plaintiff, James M. Stang, to ask questions related to Dr. Shenoy's personal health and a report prepared by a nonparty doctor during further depositions.

The case centers on allegations of medical malpractice against Dr. Shenoy, who is a physician. The court's decision is crucial as it affects the evidence that can be presented during the trial. It emphasizes the importance of full disclosure in legal proceedings, particularly in cases involving medical professionals.

The dispute arose when Stang sought to compel Dr. Shenoy to undergo further deposition. The Supreme Court of Erie County had previously granted some of Stang's requests but denied others, specifically prohibiting questions about a report by R.N. Sawyer, Jr., M.D., and Dr. Shenoy's personal health condition. Stang appealed this decision, arguing that the limitations imposed by the lower court could hinder his ability to prepare for trial.

Background

James M. Stang is the plaintiff in this medical malpractice action, while Dr. Sadashiv S. Shenoy serves as the defendant. The case began when Stang alleged that Dr. Shenoy's actions amounted to malpractice, leading to significant harm. The specifics of the alleged malpractice were not detailed in the court filing, but such cases typically involve claims of negligence or failure to provide adequate care.

The case reached the Appellate Division after Stang appealed an order from the Supreme Court, Erie County, dated April 17, 2025. This order partially granted and partially denied Stang's motion to compel further deposition from Dr. Shenoy. The plaintiff's appeal focused on the limitations placed on questioning during the deposition, which he argued were unjustified and could obstruct his case.

The Ruling

The Appellate Division ruled in favor of Stang, modifying the lower court's order. The court decided to vacate the prohibition against questioning Dr. Shenoy about the report from R.N. Sawyer, Jr., M.D., and his personal health condition. The judges involved in the ruling included Bannister, Montour, Greenwood, and Hannah.

The court ruled, "the limitation could result in the preclusion of testimony that would be relevant at trial or in preparation for trial."

This statement highlights the court's view that the information sought by Stang is essential for a fair trial. The judges emphasized the need for full disclosure in legal proceedings, particularly under the CPLR 3101 (a), which mandates that parties should have access to all material and necessary information for their case.

The court also noted that the report prepared by Dr. Sawyer was made public in a separate action, which meant it was not protected by any statutory privilege. This aspect of the ruling reinforces the idea that once information is disclosed publicly, it can be used in related legal matters.

Impact

This ruling has significant implications for medical malpractice cases in New York. By allowing questions about Dr. Shenoy's health and the report from Dr. Sawyer, the court has set a precedent that emphasizes the importance of transparency in legal proceedings. It reinforces the principle that parties involved in litigation should have access to all relevant information that could impact the outcome of the case.

The decision may also encourage other plaintiffs in medical malpractice cases to seek similar disclosures, knowing that courts may be inclined to support full transparency. This could lead to more comprehensive investigations into the practices and health of medical professionals accused of malpractice.

What's Next

Following this ruling, the case will continue as Stang prepares for further deposition of Dr. Shenoy. The decision can be appealed, but details regarding any potential appeal were not available in the court filing. There are no related cases mentioned, but the outcome of this case could influence future medical malpractice actions in New York.