The advancement of robotic surgical systems has fundamentally transformed medicine by enhancing precision, minimizing tissue damage, and improving clinical outcomes. However, this technology raises significant legal issues concerning the civil liability of surgeons and robot manufacturers. Comparative analysis using a descriptive–analytical approach in Iranian and English legal systems indicates that in Iran, civil liability primarily relies on fault, whereas in England, in addition to fault-based liability, contractual liability and strict product liability are recognized. In Iran, the absence of specialized legislation and clear legal frameworks complicates proving liability in robotic surgery disputes. Allocation of responsibility is generally equal unless otherwise demonstrated. Conversely, English law applies proportional liability, apportioning responsibility according to each party’s contribution to harm, which enhances judicial fairness. Evidentiary challenges in Iran stem largely from the lack of technical and legal expertise in courts and outdated regulations, making dispute resolution complex. In England, comprehensive legislation, judicial specialization, and shifting the burden of proof to manufacturers facilitate litigation and ensure more predictable outcomes. To address these gaps, Iran requires dedicated legislation, specialized judicial structures, and advanced professional training in emerging medical technologies. Such reforms would not only ensure effective patient protection but also foster innovation in digital medicine. By aligning liability principles with technological advancements, the legal system can balance accountability, patient safety, and the development of modern medical practices, thereby supporting both legal certainty and the evolution of healthcare innovation.