Author Name:   Prarthana

The article traces and analyses the concept of vicarious liability of the state in performance of its sovereign functions, through case law - both pre-constitutional and post-constitutional...

Vicarious Liability:
Vicarious liability is a form of strict, secondary liability that arises under the common law doctrine of agency – respondeat superior – the responsibility of the superior for the acts of their subordinate, or, in a broader sense, the responsibility of any third party that had the "right, ability or duty to control" the activities of a violator. The liability is placed, not on the tortfeasor, but rather on someone who is supposed to have control over the tortfeasor.

The most common form of vicarious liability that we come across is the liability arising out of a ‘Master – Servant’ relationship. This is sometimes referred to as the doctrine of "RESPONDEAT SUPERIOR" (in which the MASTER - the archaic term for an employer - must respond for the torts of its SERVANTS - the archaic term for employees)1. The principle says that a master is jointly and severely liable for any tort committed by his servant while acting in the course of his employment. As Lord Brougham said: “The reason that I am liable is this, that by employing him I set a whole thing in motion; and what he does, being done for my benefit and under my direction, I am responsible for the consequences of doing it. This implies that the liability for the injured party’s loss is properly shifted to the person or entity whose enterprise was benefited by the relationship, and created the occasion for the wrongdoer’s act or omission.

When a servant commits a tort in the course of his employment, the master is very often guilty of what German lawyers call “Culpa in eligendo” or “Culpa in inspiciendo” In order that the doctrine of vicarious liability may apply, the conditions that need to be fulfilled are that firstly, the relationship of master and servant must exist between the defendant and the person committing the wrong complained of. Secondly, the servant must in committing the wrong have been acting in the course of his employment.

State Liability :
Under the English Common Law the maxim was "The King can do no wrong" and therefore, the King was not liable for the wrongs of its servants. But, in England the position of old Common law maxim has been changed by the Crown Proceedings Act, 1947. Earlier, the King could not be sued in tort either for wrong actually authorised by it or committed by its servants, in the course of their employment. With the increasing functions of State, the Crown Proceedings Act had been passed, now the Crown is liable for a tort committed by its servants just like a private individual. Similarly, in America, the Federal Torts Claims Act, 1946 provides the principles, which substantially decides the question of liability of State.

In ancient India, under the Hindu jurisprudence, it was an undisputed principle that no one is exempted from the operation of law. This liability to equal punishment extended even to the king, relative of the king, a judge or an ordinary citizen. The rule of law was considered supreme and binding on everyone alike. The important functions of the king were concerned with protection of people, punishment of crimes and maintenance of dharma or social order.

In the medieval Indian history the personal liability of officers for their wrongs was more vogues with evidences showing equality between the ruler and the ruled subject. Only when the king considered it proper to undertake the burden of public officer, it was then the state treasury used to pay the compensation. Dharma was considered the administrative law binding the king as well as the subjects. Both in Hindu law and Muslim law, the rulers themselves administered justice as far as possible and the rest was done by the exceptionally learned and honest judges. The most significant recent trend has been an assertion on the part of the court that it has a power to grant compensation. The principle of personal liability of public servants for wrongs done to citizens is already a part of Indian law based on English case laws.

Presently State liability in India is defined by the Article 300(1) of the Constitution that originated from Section 176 of the Government of India Act, 1935. This could be traced back from the Section 32 of the Government of India Act, 1915, the genesis of which can be found in Section 65 of the Government of India Act, 1858. It will thus be seen that by the chain of enactment beginning with the Act of 1858, the Government of India and Government of each State are in line of succession of the East India Company. In other words, the liability of the Government is the same as that of the East India Company before, 1858.

Sovereign Functions :
Sovereign functions are those actions of the state for which it is not answerable in any court of law. For instance, acts such as defence of the country, raising and maintaining armed forces, making peace or war, foreign affairs, acquiring and retaining territory, are functions which are indicative of external sovereignty and are political in nature. Therefore, they are not amenable to jurisdiction of ordinary civil court. The State is immune from being sued, as the jurisdiction of the courts in such matters is impliedly barred.

The distinction between sovereign and non-sovereign functions was considered at some length in N. Nagendra Rao v. State of AP. All the earlier Indian decisions on the subject were referred to. The court enunciated the following legal principles, in its judgment:

In the modern sense, the distinction between sovereign or non-sovereign power thus does not exist. It all depends on the nature of the power and manner of its exercise. Legislative supremacy under the Constitution arises out of constitutional provisions. The legislature is free to legislate on topics and subjects carved out for it. Similarly, the executive is free to implement and administer the law. A law made by a legislature may be bad or may be ultra vires, but, since it is an exercise of legislative power, a person affected by it may challenge its validity but he cannot approach a court of law for negligence in making the law. Nor can the Government, in exercise of its executive action, be sued for its decision on political or policy matters. It is in public interest that for acts performed by the State, either in its legislative or executive capacity, it should not be answerable in torts. That would be illogical and impractical. It would be in conflict with even modern notions of sovereignty.

Pre-Constitution Judicial Decisions :
1. Peninsular & Oriental Steam Navigation Company v Secretary :
A consideration of the pre-Constitution cases of the Government’s liability in tort begins with the judgment of the Supreme Court of Calcutta in the case. P. & O. Steam Navigation Co. v. Secretary of State .

The principle of this case holds that if any act was done in the exercise of sovereign functions, the East India Company or the State would not be liable. It drew quite a clear distinction between the sovereign and non-sovereign functions of the state.

As the facts of the case go, a servant of the plaintiff-company was proceeding on a highway in Calcutta, driving a carriage which was drawn by a pair of horses belonging to the plaintiff. He met with an accident, caused by negligence of the servants of the Government. For the loss caused by the accident, the plaintiff claimed damages against the Secretary of State for India.

The Supreme Court observed that the doctrine that the ‘King can done wrong’, was applicable to the East India Company. The company would have been liable in such cases and the Secretary of State was thereafter also liable. This arose out of the section 65, Government of India Act, 1858, which equated the liability of the Secretary of State for India with that of the East India Company. Distinguishing between sovereign and non-sovereign functions it was held that if a tort were committed by a public servant in the discharge of sovereign functions, no action would lie against the Government – e.g. if the tort was committed while carrying on hostilities or seizing enemy property as prize.

This doctrine of immunity, for acts done in the exercise of sovereign functions, was applied by the Calcutta High Court in Nobin Chander Dey v. Secretary of State. The plaintiff in this case contended that the Government had made a contract with him for the issue of a licence for the sale of ganja and had committed breach of the contract. The High Court held that upon the evidence, no breach of contract had been proved. Secondly even if there was a contract, the act had been done in exercise of sovereign power and was thus not actionable.

2. Secretary of State v. Hari Bhanji :
In this case, the Madras High Court held that State immunity was confined to acts of State. In the P & O Case, the ruling did not go beyond acts of State, while giving illustrations of situations where the immunity was available.

It was defined that Acts of State, are acts done in the exercise of sovereign power, where the act complained of is professedly done under the sanction of municipal law, and in exercise of powers conferred by law. The mere fact that it is done by the sovereign powers and is not an act which could possibly be done by a private individual does not oust the jurisdiction of the civil court.

The Madras judgment in Hari Bhanji holds that the Government may not be liable for acts connected with public safety, even though they are not acts of State. This view was re-iterated in Ross v. Secretary of State. The Allahabad High Court took a similar view in Kishanchand v. Secretary of State.

However, in Secretary of Secretary of State v. Cockraft, making or repairing a military road was held to be a sovereign function and the Government was held not liable, for the negligence of its servants in the stacking of gravel on a road resulting in a carriage accident that injured the plaintiff.

Other such cases :
In the Bombay case of Rao v. Advani, it was held that the Madras view in the Hari Bhanji case was correct. The Bombay case was not one of a claim to damages for tort, but related to a petition for certiorari to quash a Government order for the requisitioning of property, as proper notice had not been given. On appeal, the Supreme Court, in the case of State of Bombay v. Khushaldas Advani, reversed the High Court, holding that natural justice was not required to be observed, before requisitioning any property. The definition of “act of State” given in Eshugbayi v. Government of Nigeria was recognised and accepted.

Post Constitution Judicial Decisions
1. State of Haryana v. Santra
The ratio of this case was on the principles of state liability for negligence. Here it was clearly established that the doctor while performing the operation was acting as a government servant and acting in the course of employment of the government. Hence when there was negligence, it amounted to acting in bad faith, and so the defence of sovereign immunity could not be used by the state. Moreover it was also held that such negligence which could have been perceived by a professional who had a duty to do so should take into consideration these matters and cannot escape liability by claiming defence of consent by the petitioner.

The respondent in the above case was a poor lady who went under a sterilization operation at the General Hospital, Gurgaon, as she already had seven children and wanted to take advantage of the family planning scheme launched by the State Government of Haryana. Smt. Santra was informed that she would not conceive in future. Smt. Santra approached the Chief Medical Officer, Gurgaon, for her sterilization in 1988. But she gave birth to a female child. This led her to file a suit claiming Rs. 2 lakhs as damages for medical negligence due to “failed sterilization” which was decreed for a sum of Rs. 54,000/- with interest at the rate of 12 per cent per annum from the date of institution of the suit till the payment of the decretal amount. Two appeals were filed against this decree in the court of District Judge, Gurgaon, which were disposed of by Addl. District Judge, Gurgaon, by a common judgment dated 10.5.1999. Both the appeals - one filed by the State of Haryana and the other by Smt. Santra were dismissed. The second appeal filed by the State of Haryana was summarily dismissed by the Punjab & Haryana High Court on 3.8.1999.

There are two major issues involved in the case. One is that there was negligence on the part of the doctor who operated on her as the operation was a failure. Moreover as the operation took place in a Government Hospital, the state should be vicariously liable for the negligent act of its servant in the course of employment. This law also deals with the Hindu Adoptions and Maintenance act, 1956, Ss.20 and 23.the principle involved for the above claim is the vicarious liability of the state for the negligence of its doctors.

In reply to the claim of compensation of Rs. 2 lakhs by the respondent, the officers defending the state argued that during the time of the operation only the right Fallopian tube was operated on and the left tube was left untouched. The appellants also argued that the negligence on the part of the doctors would not make the state vicariously liable and that the damages paid to her for the maintenance of the child could not be decreed as there was no element of tort involved. It was further pleaded that Smt. Santra had herself put her thumb impression on a paper containing a recital that in case the operation was not successful, she would not claim any damages. It was pleaded that she was estopped from raising the plea of negligence or from claiming damages for an unsuccessful sterilization operation from the State.

After the District Court dismissed the matter giving a compensation of Rs 54,000 and an interest rate of 12% per annum, the State filed a suit in the Supreme Court challenging the decision. Due to the failure of the operation and the conceivement of the child, the respondent had filed a suit claiming for damages worth Rs. 2 lakhs for the maintenance of the child and herself as she already as seven children. The respondent claimed that if she had offered herself for complete sterilization operation, both the Fallopian tubes should have been operated upon. The doctor who performed the operation acted in the most negligent manner.

Moreover she also stated that as the operation was carried out in a government hospital and the doctor being a government servant, the state was vicariously liable for the act of the doctor as a servant of the State.

Judgment:
The explanation given by the appellants for absence of state liability was rejected by the trial court which the suit for a sum of Rs. 54,000 with pendate lite and future interest at 12% per annum. The decision was confirmed by the Appellant Court and State High Court. The trial court as also the lower appellate court both recorded concurrent findings of fact that the sterilisation operation performed upon Smt. Santra was not 'complete' as in that operation only the right Fallopian Tube was operated upon while the left Tube was left untouched. The courts were of the opinion that this exhibited negligence on the part of the Medical Officer who performed the operation. Smt. Santra, in spite of the unsuccessful operation, was informed that sterilisation operation was successful and that she would not conceive any child in future. The plea of estoppel raised by the defendants was also rejected. The amount of Rs. 54,000/- which has been decreed by the courts below represents the amount of expenses which Smt. Santra would have to incur at the rate of Rs. 2,000/- per annum in bringing up the child up to the age of puberty.

Having regard to the above facts the court said that Smt. Santra was entitled to full compensation from the State Government and appeal was dismissed but without any order as to cost.

Post Judgement Developments:
In case of any medical negligence, if the doctor acting in the course of employment of the Government Hospital, the Government is liable for the negligent act as it come under the preview of State Liability. In the case of State of Punjab v. Shiv Ram & ors., cause of action for claiming compensation in cases of failed sterilization operation arises on account of negligence of surgeon and not on account of child birth.

In the case of The Joint Director of Health Services v. Sahai, death of patient occurred due to negligence in carrying out operation. The post-operation treatment done by defendant No. 2 was not proper. Defendant No. 1 unauthorized delegated function to defendant No. 2 who removed stitches of patient without taking precautions and thus due to negligence of defendants No. 1 and 2 patient died. Following the same principle of infringement of Right to Life, State was held vicariously liable for damages on account of negligence of its doctors or other employees. Again in the case of Dr. M.K.Gaurikutty v. M.K. Raghavan, proper care was not taken by defendants due to which damage to brain not avoided. Patient was admitted to hospital for purpose of treatment but patient was not particular about doctor. Due to negligence of doctor or staff any mishap happens hospital authorities responsible. Government could not produce any record to show that there was no negligence, hence State was held vicariously liable.

2. State of Rajasthan v. Vidyawati :
The respondents filed a suit for the damages made by an employee of a State and the case questioned whether the State was liable for the tortious act of its servant – The Court held that the liability of the State in respect of the tortious act by its servant within the scope of his employment and functioning as such was similar to that of any other employer.

It was held in this case that the State should be as much liable for tort in respect of tortuous acts committed by its servant within the scope of his employment and functioning as such, as any other employer.

The facts of this case may shortly be stated as follows. The first defendant Lokumal, was a temporary employee of the appellant State, as a motor driver on probation. In February, 1952, he was employed as the driver of a Government jeep car, registered as No. RUM 49, under the Collector of Udaipur. The car had been sent to a workshop for necessary repairs. After repairs had been carried out, the first defendant, while driving the car back along a public road, in the evening of February 11, 1952, knocked down one Jagdishlal, who was walking on the footpath by the said of the public road in Udaipur city, causing him multiple injuries, including fractures of the skull and backbone, resulting in his death three days later, in the hospital where he had been removed for treatment. The plaintiffs who are Jagdishlal's widow and a minor daughter, aged three years, through her mother as next friend sued the said Lokumal and the State of Rajasthan for damages for the tort aforesaid. They claimed the compensation of Rs.25,000/- from both the defendants. The first defendant remained ex-parte. The suit was contested only by the second defendant on a number of issues. Both the Courts below have agreed in finding that the first defendant was rash and negligent in driving the jeep car resulting in the accident and the ultimate death of Jagdishlal. The second defendant, who was the respondent in the High Court, and is the appellant before us, contested the suit chiefly on the ground that it was not liable for the tortious act of its employee. The Trial Court, decreed the suit against the first defendant ex-parte, and dismissed it without costs against the second defendant. On appeal by the plaintiffs, the High Court of Rajasthan allowed the appeal and decreed the suit against the second defendant also, with costs in both the Courts. The State of Rajasthan applied for and obtained the necessary certificate that the case fulfils the requirements of Art. 133(1)(a) of the Constitution of India. High Court rightly observed that an important point of law of general public importance, namely, the extent of the liability of the State, in tort, was involved.

Judgement :
In State of Rajasthan V. Vidyawati, the Supreme Court reviewed the position of law, under article 300 of the Constitution, and the facts and circumstances leading to the formation of the State of Rajasthan.

The State of Rajasthan has not shown that the Rajasthan Union, its predecessor, was not liable by any rule of positive enactment or by Common Law. The Dominion of India, or any constituent Province of the Dominion, would have been liable in view of the provisions aforesaid of the Government of India Act, 1858. No provision of law, statutory or otherwise, was presented, that could exonerate the Rajasthan Union form vicarious liability for the acts of its servants. It has not been claimed before us, that the common law of the United Kingdom, before it was altered by the said Act with effect from 1948, applied to the Rajasthan Union in 1949, or even earlier. It must, therefore, be held that the State of Rajasthan has failed to discharge the burden of establishing the case.

The immunity of the Crown in the United Kingdom was based on the old feudalistic notions of justice, namely, that the King was incapable of doing a wrong, and, therefore, of authorising or instigating one, and that he could not be sued in his own courts. In India, ever since the time of the East India Company, the sovereign has been held liable to be sued in tort or in contract. The constitution has established a Republican form of Government, and one of the objectives is to establish a Socialistic State with its varied industrial and other activities. Thus, there is no justification, in principle, or in public interest, for the State not to be held liable vicariously for tortious acts of its servant. The Court deliberately departed from the Common Law rule that a civil servant cannot maintain a suit against the Crown. When the rule of immunity in favour of the Crown, based on Common Law in the United Kingdom, has disappeared from the land of its birth, there is no legal warrant for holding that it has any validity in this country, particularly after the Constitution. As the cause in this case arose after the coming into effect of the Constitution, it is only recognising the old established rule, going back to more than 100 years at least, in upholding the vicarious liability of the State. Article 300 of the Constitution itself has saved the right of Parliament or the Legislature of a State to enact such law as it may think fit and proper in this behalf. But, so long as the Legislature has not expressed its intention to the contrary, it must be held that the law is what it has been, ever since the days of the East India Company.

3. Kasturilal v. State of UP
The ruling in this case was given holding that the act, which gave rise to the present claim for damages, has been committed by the employee of the respondent during the course of its employment. Also, that employment belonged to a category of sovereign power. This removed any liability on the part of the state.

In this case, the plaintiff had been arrested by the police officers on a suspicion of possessing stolen property. Upon investigation, a large quantity of gold was found and was seized under the provisions of the Code of Criminal Procedure. Ultimately, he was released, but the gold was not returned, as the Head Constable in charge of the maalkhana, where the said gold had been stored, had absconded with the gold. The plaintiff thereupon brought a suit against the State of UP for the return of the gold or alternatively, for damages for the loss caused to him. It was found by the courts below, that the concerned police officers had failed to take the requisite care of the gold seized from the plaintiff, as provided by the UP Police Regulations.

Judgment:
The trial court decreed the suit, but the decree was reversed on appeal by the High Court. When the matter was taken to the Supreme Court, the court found, on an appreciation of the relevant evidence, that the police officers were negligent in dealing with the plaintiff’s property and also, that they had not complied with the provisions of the UP Police Regulations. However, the Supreme Court rejected the plaintiff’s claim, on the ground that “the act of negligence was committed by the police officers while dealing with the property of Ralia Ram, which they had seized in exercise of their statutory powers. The power to arrest a person, to search him and to seize property found with him, are powers conferred on the specified officers by statute and they are powers which can be properly categorized as sovereign powers. Hence the basis of the judgment in Kasturi Lal was two-fold - The act was done in the purported exercise of a statutory power. Secondly, the act was done in the exercise of a sovereign function.

Other Important Milestones :
1. Challa Ramkonda Reddy Vs. State of AP:
In the judgment of the High Court of Andhra Pradesh in Challa Ramkonda Reddy Vs. State of AP, it was held that the plea of sovereign immunity was not available, where there was a violation of the fundamental rights of the citizens. It was a case where a person arrested by the police was lodged in a cell in the jail. He expressed his apprehension to the authority in charge of the jail, that his enemies were likely to attack and kill him in the jail. This apprehension was not given any consideration by the authorities. During the particular night, there were only two persons guarding the jail, instead of the usual six. The enemies of the arrested person entered the jail during the night and shot him dead. The legal representatives of the deceased filed a suit for damages. The trial court found that the authorities were negligent in guarding the jail and that the death of the deceased was attributable to such negligence. However, the suit was dismissed on the ground that the arrest and detention of the deceased in jail was in exercise of sovereign functions of the State. During the hearing of the plaintiff’s appeal, the State relied upon the decision of the Supreme Court in Kasturi Lal. The High Court, however, held that where the fundamental rights of the citizens are violated, the plea of sovereign immunity, which is assumed to be continued by article 300 of the Constitution, cannot be put forward. This view has been approved by the Supreme Court in AIR 2000 SC 2083. [State of A.P. v. Chella Ramakrishna Reddy].

2. Saheli V. Commissioner of Police:
Saheli V. Commissioner of Police was another milestone in the evaluation of compensation jurisprudence in writ courts. The masterpiece judgement in Vidyawati, which was freezed by Kasturi Lal was rightly quoted in this case. The State was held liable for the death of nine year old child by Police assault and beating. Delhi Administration was ordered to pay compensation of Rs. 75000/-. The significance of this case is that firstly, the revival of Vidyawati ratio and secondly that the Delhi Administration was allowed to recover money from those officers who are held responsible for this incident.

3.Nilabati Behra V. State of Orissa :
Another landmark judgement was Nilabati Behra V. State of Orissa awarding compensation to the petitioner for the death of her son in police custody. The court held that a claim in public law for compensation for violation of human rights and fundamental freedoms, the protection remedy for enforcement and protection of such right, is distinct from and in addition to the remedy in private law damages for tort. The court expressly held that principle of sovereign immunity does not apply to the public law remedies under Article 32 and Article 226 for the enforcement of fundamental rights. The Kasturi Lal case ratio is confined to private law remedies only.

The distinction between public and private law and the remedies under the two has been emphasised in Common Cause, A Registered Society V. Union of India and Chairman, Railway Board V. Chandrima Das cases. It was held "where public functionaries are involved and the matter relates to the violation of fundamental rights or the enforcement of public duties, the remedy would still be available under the public law notwithstanding that a suit could be filed for damages under private law."

Conclusion :
In all the cases discussed before, the entity sought to be made liable is not the government but the State. So far as the government is concerned, it may well say that the statutory authority is neither accountable nor subordinate to it. Hence the government cannot be visited with the consequences flowing from a wrong order made by a statutory authority. As far as the State is concerned, it cannot put forward any such plea inasmuch as the statute is enacted by it by Legislature. The appointment of the authority is also done either by the Statute itself or by such authority as may be authorised by the Statute. The act of the statutory authority in such a case is an act done for and on behalf of the State. Hence the state is held liable.

State’s liability for the acts or omissions of statutory authorities arises only in cases where the statutory authority acts outside his legal authority while purporting to act pursuant to the legal authority conferred upon him and the act or omission, which causes or results in damage to a person, is not within the ambit of the statutory protection, if any, contained in such enactments. This rule is evolved for the obvious reason that an act done under a statute and in accordance with the statute can never amount to a tort as was said by the Supreme Court in Martin Burn Ltd. Vs. Calcutta Corporation. The Court said “A result flowing from a statutory provision is never an evil”.

“The Government of India may sue or be sued by the name of the Union of India and the Government 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 the Legislature of such State enacted by virtue 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 Provinces or the corresponding Indian States might have sued or been sued if this Constitution had not been enacted.”

"All persons and bodies politic shall and may have and take the same suits, for India as they could have done against the said Company."
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# N. Nagendra Rao v. State of AP AIR 1994 SC 2663
# Peninsular & Oriental Steam Navigation Company v Secretary (1861) 5 Bom HCR App I p.1
# Nobin Chander Dey v. Secretary of State I.L.R. 1 Cal. 11
# Secretary of State v. Hari Bhanji ILR (1882) 5 Madras 273
# Ross v. Secretary of State [1913] 37 Mad. 55
# Kishan Chand Vs. Union of India ILR (1974) II Delhi 637
# Secretary of State v. Cockraft AIR 1915 Mad. 993; (1916) ILR 39 Mad. 351
# Province of Bombay v. Khushaldas S Advani AIR 1950 Supreme Court 222
# State of Haryana & Ors. v. Smt. Santra, 2000 (1) CPJ 53 (SC)
# Punjab v. Shiv Ram & ors JT 2005 (7) SC 606
# Joint Director of Health Services v. Sahai AIR 2000 Mad. 305
# State of Rajasthan Vs. Vidyawati, AIR 1962 SC 933
# An appeal shall lie to the Supreme Court from any judgment , decree or final order in a civil proceeding of a High Court in the territory of India that the case involves substantial question of law of general importance.
# Kasturilal v State of U.P. AIR 1965 S.C 1039 at 1046
# Challa Ramakonda Reddy v. State of A.P A.I.R 1989 A.P. 235
# Saheli V. Commissioner of Police A.I.R 1990 S.C. 513
# Nilabati Behara Vs. State of Orissa, AIR 1993 SC 1960
# Common Cause, A Registered Society V. Union of India AIR 1996 SC 3538
# Chairman, Railway Board V. Chandrima Das AIR 2000 SC 988 : (2000) 2 SCC 465
# Martin Burn Ltd. Vs. Calcutta Corporation AIR 1966 SC 529 at 535

The  author can be reached at: prarthana@legalserviceindia.com

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