Facts of the Case
A pedestrian was lawfully walking on a public road when a State-owned vehicle, driven by a government employee in the course of his official duty, was driven in a rash and negligent manner. As a result of the negligent driving, the pedestrian sustained fatal injuries and died on the spot. The deceased was the sole earning member of the family, and his legal heirs were financially dependent on him. After the incident, the State authorities admitted that the vehicle belonged to the government and that the driver was a government servant acting during working hours. However, the State denied liability by claiming sovereign immunity, arguing that the act was performed during official duties. The legal heirs approached the court seeking compensation from the State for wrongful death caused by negligence.
Issues in the Case
- Whether the State can be held vicariously liable for the negligent act of its employee driving a government vehicle.
- Whether the doctrine of sovereign immunity protects the State from liability in cases of motor vehicle accidents.
- Whether the legal heirs of the deceased pedestrian are entitled to compensation from the State under Administrative Law and tort principles.
- Whether negligent driving of a government vehicle amounts to a non-sovereign function of the State.
Legal Principles Covered to Support Case Proceedings and Judgment
Under Indian Administrative Law, the State can be held liable for tortious acts committed by its servants while performing non-sovereign functions. The landmark case of State of Rajasthan v. Vidyawati (1962) established that when a government employee negligently drives a State vehicle and causes death, the State is vicariously liable to compensate the victims. The Supreme Court held that driving a vehicle is not a sovereign function but a routine administrative activity.
Further, in Kasturi Lal v. State of U.P. (1965), the Court distinguished between sovereign and non-sovereign functions, limiting State immunity only to acts strictly connected with sovereign powers such as defense and law enforcement. Motor vehicle operation does not fall under sovereign functions.
Additionally, Article 300 of the Constitution of India allows suits against the State in the same manner as against a private individual. Compensation can also be claimed under public law remedy for violation of the right to life under Article 21, as recognized in Nilabati Behera v. State of Odisha (1993).
Possible Judgment
The court is likely to hold that the State is vicariously liable for the negligent act of its employee. Since driving a government vehicle is a non-sovereign function, the defense of sovereign immunity is not applicable. The legal heirs of the deceased pedestrian are entitled to monetary compensation from the State for loss of life, dependency, and emotional suffering. The court may direct the State to pay compensation under tort law principles and may allow the State to recover the amount from the negligent employee through departmental proceedings. Thus, the heirs would succeed in their claim.
About lawgnan
Administrative Law concepts like State liability, sovereign immunity, and vicarious liability are frequently tested in LLB examinations. Understanding case-based answers helps students score high in problem questions. For more exam-ready case analyses, simplified explanations, real-time illustrations, and updated legal notes, visit lawgana.in. LawGana is designed exclusively for Indian law students preparing for LLB, judiciary, and competitive exams. Follow lawgana.in to strengthen your conceptual clarity and improve answer-writing skills with structured legal content.
