THE NATIONAL LAW

INSTITUTEUNIVERSITY, BHOPAL

LAW OF TORTS-1
SEMESTER 1

TOPIC: TORTIOUS LIBALITY UNDER A-300

SUBMITTED BY: SUBMITTED TO:

Pragya Somkunwar Prof. (Dr.) Rajiv Khare
Roll no.: 2021BALLB117
Enrolment no.: A-2414

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 DECLARATION
I, PRAGYA SOMKUNWAR D/O NARESH SOMKUNWAR, Roll Number:
2021BALLB117, Enrolment Number: A-2414 do hereby declare that the Project titled
“TORTIOUS LIBALITY UNDER A-300” is an outcome of my own independent research
endeavour and has been carried out under the guidance of Prof. (Dr.) Rajiv Khare. Literature
relied on by me for the purpose of this Project has been fully and completely acknowledged
in the footnotes and bibliography. The Project is not plagiarized and all reasonable steps have
been taken to avoid plagiarism. Similarity Index as per the Turnitin Report is ____%. In case,
my project is found to be plagiarized, the course teacher shall have the full liberty to ask me
to revise the Project. If I fail to comply with the instructions of the teacher, my project may
be referred to the Committee against Use of Unfair Means and I will comply with the
decision of the said Committee. At the end I would like to thank Gyan Mandir, NLIU
officials for helping me find the research material appropriate for this study. I also wish to
extend my thanks to the authority of the university. I also wish to express my gratitude to my
friends and family who helped me complete this project successfully.

Date:
Professor Signature: Student Signature:

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 ACKNOWLEDGMENT

The unconditional support of many people has made this project possible. I wish to
express my sincere gratitude to Prof. (Dr.) Rajiv Khare who helped me to develop this
project into a coherent whole through his helpful insight and brilliant know-how. I also
thank Gyan Mandir, NLIU officials for helping me find the research material
appropriate for this study. I also wish to extend my thanks to the authority of the
university and to my friends and family who helped me in completion of this project
successfully.

Pragya Somkuwar
(2021BALLB117)

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TABLE OF CASES:

1. Bhim Singh v. State of Jammu and Kashmir AIR 1986 SC 494, 1986 CriLJ 192, 1985
(2) SCALE 1117, (1985) 4 SCC 677, 1986 (1) UJ 458 SC
2. Kasturi Lal Ralia Ram Jain v. State of U.P 1965 AIR 1039, 1965 SCR (1) 375
3. MC Mehta v. UOI [1987] 1 SCC 395

4. Nilabati Behra Alias Lalita v. State of Orissa & Ors.[AIR 1993,SC 1960]

5. P & O steam Navigation Co.v. Secretary of State (1869) 5 Bom HCR App 1

6. Rylands v. Fletcher [1868] LR 3 HL 330

7. Rudal Shah v. State of Bihar 1983 AIR 1086, 1983 SCR (3) 508

8. State of Rajasthan v. Vidyawati, AIR 1962 SC 933

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TABLE OF CONTENTS
INTRODUCTION......................................................................................................................7
LITERATURE REVIEW...........................................................................................................9
OBJECTIVES OF THE STUDY...............................................................................................9
HYPOTHESIS.........................................................................................................................10
STATEMENT OF PROBLEM................................................................................................10
RESEARCH METHODOLOGY.............................................................................................10
RESEARCH QUESTIONS......................................................................................................10
TORTIOUS LIABILITY.........................................................................................................11
TYPES OF LIABILITY...........................................................................................................12
 Fault based liability......................................................................................................12
 Non fault based liability...............................................................................................12
STRICT LIABILITY...............................................................................................................13
ESSENTIALS OF STRICT LIABILITY.............................................................................14
Rylands v. Fletcher...................................................................................................................15
INDIAN CASES IN WHICH IT IS CITED.........................................................................16
ABSOLUTE LIABILITY........................................................................................................17
ESSENTIALS OF ABSOLUTE LIABILITY......................................................................17
MC MEHTA V. UOI...............................................................................................................18
UNDERSTANTION TORTIOUS LIABILITY UNDER A-300............................................20
 Sovereign and Non sovereign functions......................................................................21
CONCLUSION........................................................................................................................23
BIBLIOGRAPHY....................................................................................................................24

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 INTRODUCTION

“A tort is a civil wrong for which the remedy is an action for unliquidated damages and
which is not exclusively the breach of a contract, or the breach of a trust, or the breach of
other merely equitable obligation.”-

Salmond

French speaking lawyers and judges of the Courts of Normandy and Angevin Kings of
England introduced the term ‘Tort’. Tort has retrieved a special meaning as a common
characteristic of civil wrong.

Tort is a French word which means wrong in English and in the Roman law it is termed as
‘Delict’. The word tort is obtained from the Latin word named ‘tortum’ which means wrong,
crooked or twisted. Tortum is the opposite word of rectum which means straight. Hence we
can derive that tort is a conduct which is not straight.

“Tort is an act or omission (not merely the brach of a duty arising out of personal relatios, or
undertaken by a contract which related to harm suffered by a determinate person, giving rise
to a civil remedy which is not an action of contract.”-

Pullock

A common notion can be understood that where there is right of person and if that legal right
is infringed by another person then the person whose right has been infringed has a legal
remedy in a court of law. As the maxim ‘Ubi jus, ibi remedium’ says where there is a right
there is a remedy.

Tort has some important characteristics:

 A tort is a civil wrong

 A tort is an infringement of a right in rm
 Torts deal with cases related to legal rights
 Remedy in the form of compensation
 Rights are to be fixed by law
 Law of torts is totally based on precedents

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  Tort law is uncodified

What put torts law out of the box is the unlimited scope and ability to keep on evolving from
time to time according to the needs of the society.

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 LITERATURE REVIEW

1. RK Bangia, LAW OF TORTS (24th edition, Allahabad Law Agency 2019)

 This book by RK Bangia is very helpful in deeply understand the concepts
of tort laws and helps us in understanding the concept of liability
thoroughly.

2. Ratanlal & Dhirajlal: Law of Torts (PB), 28th ed Ratanlal & Dhirajlal
 This book make the concept easier for me and it provided me a clear
picture about Tortious Liability of State.

OBJECTIVES OF THE STUDY

1. To understand the concept of Tortious liability.

2. To understand the types of tortious liability.
3. To understand fault based liability and no fault based liability.
4. To understand the concept of strict liability and absolute liability.
5. To critically analyse the tortious liability under A-300.

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 HYPOTHESIS
As with the time various changes occur in the society and the countries develop, the
technology and science become advance, it might have paved the way for the development of
new and more firm laws for making clarification on the liableness of the state on behalf of its
servants.

STATEMENT OF PROBLEM

How the tortious liability got evolved and what are the landmark judgments related to it.
There are complications as some damages ask for fault to be proved, some type of damages
does not create liability and sometimes some conduct result in liability without any damages.

RESEARCH METHODOLOGY
Doctrinal research method is used while making this research work.

RESEARCH QUESTIONS

1. What is tortious liability?

2. What are the types of tortious liability?
3. What Article 300 states about tortious liability
4. What is strict liability and absolute liability?
5. How state can be held liable for the act of its servant?

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 TORTIOUS LIABILITY

“Tortious liability arises from the breach of a duty primarily fixed by law; this duty is
towards persons generally and its breach is redressible by an action for unliquidated
damages.”1-
Winfield
Law of tort is a general liability. Where there is no valid justification for every wrongful act,
then it means the person is liable for committing law of tort.
There is no need of specific kind of tort to be committed mere wrongful act is enough.
“Tortious liability is a legal duty to compensate someone for damages caused. It is the result
of a court’s sentence where the wrongdoer has to pay for the injury committed against the
victim.”
Liability under law of tort is a result of civil wrongs a legal situation.
Historically tort is defined as “subject to statutory intervention, a tort is a wrong which is
former times would have been remediable by one of the actions for trespass (for indirect
wrongs) or trespass upon the case (for indirect wrongs)”
So, if one’s act or omission had caused damage to another through fault the damage will
create liability on the person in the eyes of law.
A person who has committed a tort is tortfeasor and a tortfeasor has to compensate the victim
as he carries the tortious liability which he occurred by harming the victim. So we can say
that tortfeasor is liable and responsible for the damages done by him and he is bound by law
to pay the required damages to the victim.

1
W.V.H. Rogers, Winfield & Jolowicz on Tort (16 th edn, Sweet and Maxwell, 2002)

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 TYPES OF LIABILITY

There are two types of liability under law of tort and they are as follow:

 Fault Based Liability

 No Fault Based Liability

Fault Based Liability:

When a person commits a wrongful act and he is at fault but still plaintiff has to prove that
the tortfeasor’s act or conduct was either negligent or intentional.
Fault is defined as “a negligent or intentional failure to act reasonably or accordingly to law
or duty; an act or omission giving rise to a criminal indictment or a civil tort lawsuit.
Defendant’s tort must be proven to have caused the loss suffered.
Essential of fault based Liability:
 There must be any act or omission
 There must be wrongful intention
 There must be a legal damage
 There must be a loss due to the act or omission

No Fault Based Liability:

The Rule of Strict Liability also known as The Rule of No Fault Liability which means one
can be held liable without being at fault. In other words, individual have not done any
wrongful or negligent act even so, this rule claims an individual for compensation.
There two types off liability under No Fault Liability:
 Strict Liability
 Absolute Liability

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 STRICT LIABILITY
This principle was devised in late nineteenth century in the case of Rylands v. Fletcher.2The
principle of strict liability was developed from the tort of negligence, which means that if
anyone fails to do his duty or does his duty carelessly, he shall be liable for the tort of
negligence.

The principle of strict liability states that if a person does a non-natural use of the land or
stores on his land something which can cause damage to the other party and that substance
escapes, which causes mischief or cause damage to the other party, then a person is liable
under this principle.

But the difference between negligence and strict liability is that the defendant cannot take the
excuse of negligence in strict liability. The rationale behind this is that if a person keeps a
harmful thing in his premise, then he should take all the due care and caution and it he fails to
do this, then he cannot claim this defence. In this, the plaintiff has to prove that substantial
damage is caused to him.

Strict liability is also called “no fault liability” because even if there is no fault or mistake on
the part of the defendant, then also he can be made liable. It was also made clear that a thing
maybe non-natural at one place and can be natural at another place, so the thing is judged on
the basis of the place where it is kept and escaped.

ESSENTIALS OF STRICT LIABILITY

For a person to be made liable under this, following essentials must be fulfilled:

1. Dangerous thing: This simply means that only when the object that escaped from the
defendant’s property was a dangerous thing, would the defendant be responsible for
the damages. The word “dangerous” here means that the substance, if escaped from the
defendant’s property, it is likely to cause some sort of mischief. The law states that if
the owner runs from the property, objects such as gas, electricity, explosives, flag pole,
noxious gases, vibrations, poisonous trees, sewage, large quantity of water and even
damaged wires can be considered as dangerous.
2
[1868] LR 3 HL 330

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 2. Escape: For making a person liable under strict liability, escape is a necessary
condition. If a thing doesn’t escape, then there is no ground for applying this principle.
And the thing should be escaped from the premise. It is imperative to note that strict
liability doesn’t cover the damages occur within the premise.
One important case related to this essential is Cheater v. Cater.3 In this case, one
poisonous plant is planted on the land of the defendant. The branches of that tree
extended to the plaintiff’s premise. One horse belonging to the plaintiff consumed the
leaves of that poisonous yew tree and subsequently died. The defendant was made
liable under strict liability because the escape of the branches of a poisonous tree
amount to escape.
3. Non natural use of the land: The distinction between natural and non-natural use of
land was made in the case of Rylands v. Fletcher. Whether the land is used non-
naturally was determined from the circumstances and facts of the case. As mentioned
above, storage of some dangerous substance can be dangerous in one instance and
cannot be dangerous in another instance. For example, if we plant flower plants in our
garden, it is natural use of the land but if we plant yew trees, then it is non-natural use
of the land.
4. Mischief: The substance must have the capacity to cause damage and mischief for
some other party. And that mischief and damage must be foreseeable. If that mischief
causes some damage, then the defendants are made liable. And the onus of proving
this damage is on plaintiff.

Rylands v. Fletcher4
It is the landmark case in which the principle of strict liability was laid down in 1868.

FACTS: In this case, the plaintiff was John Rylands and the defendant was Thomas Fletcher.
The defendant owned a mill named Ainsworth Millin in Lancashireand the plaintiff was the
owner of the mine adjoining the defendant’s mill.To supply his mill with water, he hired the
independent contractors to build a reservoir. While constructing the reservoirs, these
independent contractors came across old abandoned mine shafts and it seemed like no one
knew about them. They didn’t exercise the reasonable care and caution. So when the

3
[1908] 1 K.B. 247
4
Rylands (n 3)

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reservoir was filled with water, these mine shafts broke and as a result, water got into the
mines of the plaintiff and caused considerable damages to him.

ISSUE: The main issue of this case was whether the defendant can be made liable, as the
work was done by the independent contractors.

DECISION: The case first went to the Liverpool Assizes. There the case was decided in the
favour of the defendant as it was said that he had no control over the independent contractors,
so he cannot be made liable.

Then, the plaintiff moved to Court of Exchequer Chamber, there the decision was overturned
and the defendant was made liable. The defendant was not made liable under trespass,
because the flooding was indirect. And he was not made liable under nuisance because it was
the mistake of the independent contractors. Then, justice Colin Blackburn made a remark,
which later evolved into the principle of strict liability. He stated that:

"The true rule of law is, that the person who for his own purposes brings on his lands and
collects and keeps there anything likely to do mischief if it escapes, must keep it in at his
peril, and, if he does not do so, is prima facie answerable for all the damage which is the
natural consequence of its escape."

Then, the defendant moved to the House of Lords, upholding the decision of the court of
Exchequer Chamber, Lord Cairns narrowed down the statement of J. Blackburn, and limited
the scope of this to “non-natural” use of land. While distinguishing between the natural and
non-natural use, he made references to the cases of Smith v. Kenrick5and Baird v.
Williamson.6 He moved the focus from the flooding of water into the mine shafts to the
construction of reservoir. Lord Cranworth stated that the defendant cannot claim the defence
of due care and caution because if a person exercised full care and caution, how the escape
happened.

House of lords decided in favour of plaintiff and made the defendant liable to pay damages to
the plaintiff. They also mentioned foreseeability of the mischief as an essential to this rule. 7

5
[1849] 7 CB 515
6
[1863] 15 CB(NS) 317
7
All Answers ltd, 'Rylands v Fletcher - Case Summary' (LawTeacher.net, December 2020)
<https://www.lawteacher.net/cases/rylands-v-fletcher.php?vref=1> accessed 28 December 2020

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 ABSOLUTE LIABILITY
The principle of strict liability was modified by the supreme court of India in a 1985 case of
MC Mehta v. UOI.8 The rationale given by the apex court was that when the principle of strict
liability was formulated, the development in the field of science and technology was not
much advance. The rule which was formulated was “any enterprise which is engaged in any
kind of hazardous or inherently dangerous material which if there might result in any kind of
harm then the enterprise would be absolutely liable to compensate to all the people who are
affected by the same.”

The court changed the principle of “no fault liability” into “no liability.” The key difference
between both was that in the former one, some defences were available but in the latter one,
no respite was given to the defendants.

Though the House of lords in Rylands v. Fletcher assumed that strict liability is absolute in
nature but this proposition was changed by the Indian judiciary in the late twentieth century.
By removing the provision of defences, the apex court made the liability under this rule more
firm.

The scope of strict liability was narrowed down by the supreme court. Also in the strict
liability, the focus was on “non-natural” use of the land but in absolute liability, the focus
shifted to “inherently dangerous activities.”

ESSENTIALS OF ABSOLUTE LIABILITY

The essentials of absolute and strict liability are almost same in the first instance. The term
“non-natural use” was changed to “dangerous or hazardous activities.” The essentials are
briefly discussed below:

1. Hazardous or inherently dangerous substance: The honourable supreme court of India

stated in its judgment that if an enterprise is involved in some hazardous activity
which can cause damage to a person or to public in general, then that can be
absolutely liable.
2. Escape: Escape is also an important essential of absolute liability. But the only
difference is that in strict liability, when the substance escapes the premises of the
defendant then only he is liable. But in absolute liability, even if the escape is within
the premises of the defendant and it causes damage to even workman appointed by the

8
[1987] 1 SCC 395 [SC]

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 defendant himself, then also the defendant can be made liable. To put it simply, the
damages are given in absolute liability for the damage caused both within and outside
the premises too.
3. Mischief: If the substance escaped kills only an individual, then also the defendants
are liable. It doesn’t have to be a public harm to claim the damages.
4. Dangerous thing: The substance stored or taken in use must be a dangerous thing
having the potential to cause major damages to the plaintiffs. If a substance is
something normal or the land is used for natural purposes, then the plaintiff/s cannot
claim or demand damages from the defendants.

MC MEHTA V. UOI9
It is the landmark judgment in which the supreme court of India propounded this principle of
absolute liability. This landmark decision was in the domain of the tort law only, but it
evolved as the constitution law principle and also catalysed the making of the legislation on
environment protection. It was done at the time; Indian judiciary was very active because of
the development and many landmark decisions made.

FACTS: In this case, a writ petition was filed by a social activist lawyer, MC Mehta against
the Shriram Foods and Fertilizers Industries which belonged to the Delhi Cloth Mills Ltd.
and demanded for the closing down of that industry. The cause of this writ was that there was
a severe leak of oleum gas which caused the death of a lawyer and caused sever ailments to
the other people living there and also to some workmen. Bhopal gas tragedy happened few
months back before this incident. So, the need of some strict action became imperative. The
writ petition was filed under article 32 and article 21 of the Constitution.

ISSUE: The main issue raised in this case was whether the factories of this nature should be
allowed to operate in dense areas of the city and if the principle of strict liability is applicable
in this case and what must be the amount of compensation granted to the plaintiffs.

DECISION: The apex court observed that the factories and industries dealing with hazardous
and inherently dangerous cannot be forced to shut down because it affects the quality of life
of all the people. The court also stated that besides hearing the writs it has the power under 32
to modify some principles too, and under this head it modified the strict liability principle.
Justice Bhagwat said in his statement that:

9
MC Mehta (n 11)

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“This rule (strict liability) evolved in the 19th century at a time when all these developments
of science and technology has not taken place. We have to evolve new principles and lay
down new norms which would adequately deal with the new problems which arise in highly
industrialized economy "

After this the court laid down the strict liability principle as:

“We are of the view that an enterprise, which is engaged in hazardous or inherently
dangerous industry which poses a potential threat to the health and safety of the persons
working in the factory and residing in the surrounding areas owes an Absolute and non-
delegable duty to the community to ensure that no harm results to anyone on account of
hazardous or inherently dangerous activity which it has undertaken.”

Then, the apex court decided for compensation and the amount to be paid to the plaintiffs.
The court in this matter said that the amount of compensation will be decided from case to
case basis, meaning that the bigger the enterprise, the bigger will be the amount of
compensation paid. The rationale behind this was that the compensation should act like
deterrent for the enterprise.

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UNDERSTANDING TORTIOUS LIABILITY UNDER A-300
Tortious liability of state means that the state is liable for the acts of its servants. State
performs its functions through human agencies. So the question arises that can the state be
held vicariously liable for the acts of its employees.

Under

Crown cannot be held liable for the wrong done by its servants. There was a conception that
“King can do no wrong.”But later this was abolished by the government’s Crown Proceeding
Act, 1947. By this act government was placed at the same position as the subjects. This
doctrine of “King can do no wrong” was never accepted in India.

“A-300(1) The governor of India may sue or be sued by the name of the union and the
Goverment of a State may sue or be sued by the name of the state and may, subject to any
provisions which may be made by Act of Parliament or of powers conferred by this
Constitution, sue or be sued in relation to their respective affairs in the like cases as the
Dominion of India and the corresponding Indian States might have sued or been sued if this
might have sued or been sued if this Constitution had not been enacted

(2) If at the commencement of this constitution

(a) any legal proceedings are pending to the Dominion of India is a party, the
Union of India shall be deemed to be substituted for the Dominion in those
proceedings; and
(b) any legal proceedings are pending to which the a Province or an Indian State is
a party, the corresponding State shall be deemed to be substituted for the Province
or the Indian State in those proceedings”10

To appreciate the concept of tortious liability of state there is a need to understand the
concept of sovereign and non sovereign functions.

10
The Constitution of India 1949

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Sovereign and non-sovereign functions

East India Company was a trading entity and it came to India with the motive of trading.
Later Mughals provided them with Diwani rights by which they acquired dual character i.e.
Trading Company and Sovereign. After some time they were given the right to acquire
territories and maintain the army on the behalf of Crown. But then Government of India Act,
1858 took sovereignty from the company. The Act allowed the Secretary of the State in
Council to sue and be sued. There was a difference between the sovereign and non sovereign
functions due to dual character of East India Company. Company was held non liable on the
basis of sovereign function and held liable on the basis of non sovereign functions.

P & O steam Navigation Co.v. Secretary of State (1869)11

An accident happened due to the negligence of government servants. In this historical case,
Sir Barnes Peacock C.J. held that the immunity which British crown enjoyed cannot be
extended to East India Company and hence the sate was liable to pay the compensation.

In this case it was cleared that what are sovereign function and what are non sovereign
functions.

State of Rajasthan v. Vidyawati12

The jeep of collector which was owned by the State of Rajasthan did the accident of a
pedestrian who died and jeep was driven by the driver who was negligently driving it. The
court held that the state is vicariously liable for wrong done by driver and it doesn’t come
under sovereign function.

Kasturi Lal Ralia Ram Jain v. State of U.P13

A person was detained on the suspicion of being in possession of stolen property later he was
made free but his property which was some gold and jewellery was not returned to him
because it was misappropriated by police constable. The complainant sued State of U.P. The
court held that state will be not liable. This diluted the observation in vidhyawati case. But

11
P & O steam Navigation Co.v. Secretary of State (1869) 5 Bom HCR App 1
12
State of Rajasthan v. Vidyawati, AIR 1962 SC 933

13
Kasturi Lal Ralia Ram Jain v. State of U.P 1965 AIR 1039, 1965 SCR (1) 375

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later they do not used the law laid down in kasturi Lal case.However this case is not
overruled till date.

Rudal Shah v. State of Bihar (1983)14

In this case the petitioner suffered an unlawful detention for about 14 years. The SC held that

1. Civil liability can arise when constitutional rights are violated.

2. Civil liability can also emerge when there is a violation of personal liberty(i.e.
A-21)

So, the petitioner was awarded with compensation.

Bhim Singh v. State of Jammu and Kashmir (1986)15

In this case, Court held that if a person complaints that his/her legal right has been infringed
the court has jurisprudence to provide the aggrieved part with monetary compensation.

Nilabati Behra v. State of Orissa (1993)16

SC held that the sovereign immunity from tortuous acts of state officials is different from
state’s liability for contravention of the fundamental right. So, the defence of sovereign
immunity finds no place in the claim for constitutional remedies under Article 32 and 226
vis-a-vis the compensation for contravention of constitutional rights.

14
Rudal Shah v. State of Bihar 1983 AIR 1086, 1983 SCR (3) 508

15
Bhim Singh v. State of Jammu and Kashmir AIR 1986 SC 494, 1986 CriLJ 192, 1985 (2) SCALE 1117,
(1985) 4 SCC 677, 1986 (1) UJ 458 SC

16
Nilabati Behra Alias Lalita v. State of Orissa & Ors.[AIR 1993,SC 1960]

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 CONCLUSION
The conclusion which can be drawn after critically analysing the project topic is that our
hypothesis was correct. After studying all the concepts related to the topic, it can be deduced
that State can be held liable for wrong done by its servant.

It can be concluded that with the advancement in the society and because of the fact that
India is a developing country, it became imperative to modify the law to suit the current
scenario and make clearer the fact of sovereign and non sovereign functions.

After the analysing the landmark judgments, it became clear that tortious liability of state is a
broader concept which includes liability of state.

Hence, we can infer that all our presuppositions were correct.

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 BIBLIOGRAPHY
BOOKS:

1. RK Bangia, LAW OF TORTS (24th edition, Allahabad Law Agency 2019)

2. Avtar Singh and Harpreet Kaur, Introduction to the Law of Torts and consumer
protection (published by lexis nexis)

ONLINE SOURCES:

 http://www.legalservicesindia.com
 https://blog.ipleaders.in/no-fault-liability
 https://indiankanoon.org
 https://www.latestlaws.com
 https://www.legalbites.in
 https://www.lawteacher.net
 https://heinonline.org
 https://swarb.co.uk
 https://www.manupatrafast.com

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