Tortious Liability in Cases of Medical Negligence

Bhai, last year CLAT UG had a question on medical negligence and I was like "kisne se pucha?" The question was on a situation where a doctor prescribed the wrong medicine to a patient, which ultimately led to her death. The question asked about the tortious liability of the doctor. Now, I know we've studied that there are two types of liability in medical negligence - negligence and negligence with intention (malice). But, in this case, the court held the doctor liable under negligence, despite there being no proof of malice. My question is, how can you prove malice in cases of medical negligence? Can't the court just say that if the doctor was so careless, it's like having malice? How to approach this question?