Clinical Investigation
Clinical investigations for medical devices in India are governed by Chapter V of MDR 2017 (Rules 37–45) and the New Drugs and Clinical Trials Rules 2019.
When clinical data is required
- Novel devices without a reference authority approval;
- Class C and D devices (may be required even with reference approval);
- Devices where bridging is not sufficient.
CDSCO permission
Form MD-24 (clinical investigation permission) or Form MD-28 (amendment) is submitted via SUGAM, along with a clinical investigation protocol reviewed and approved by a CDSCO-recognised Ethics Committee.
Official source: Medical Devices Rules 2017, Chapter V; ND&CT Rules 2019; CDSCO
Key Protocol Elements
A clinical investigation protocol for medical devices must include:
- Study objectives (primary and secondary endpoints)
- Detailed device description and its intended use
- Patient population definition, inclusion/exclusion criteria
- Study design (e.g., RCT, single-arm, non-comparative)
- Safety and efficacy assessment methods
- Statistical analysis plan with justified sample size
- Interim analysis rules (if applicable)
- Safety monitoring and stopping rules
- Data management and quality assurance procedures
- Insurance/compensation arrangements for study participants
- Timeline and milestones
CDSCO expects protocols to follow good clinical practice (GCP) principles. Protocols adapted from international studies should be justified for applicability to the Indian patient population.