NATIONAL LAW INSTITUTE UNIVERSITY

BHOPAL

LAW OF TORTS- I

TRIMESTER-I

TOPIC- TORTIOUS CLAIMS AGAINST THE STATE IN

NEGLIGENCE

SUBMITTEDTO:- SUBMITTED BY :-

Prof.(Dr.) Rajiv Kumar Khare Tanya Shukla

2019BA LLB59

Enrollment number- A-2101

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 CERTIFICATE

This is to certify that the project titled ‘Tortious Claims against the state in
Negligence’ has been prepared and submitted by Tanya Shukla, who is
currently pursuing her B.A.LLB. (Hons.) in the first year of study.

-Tanya Shukla(2019B.A.LL.B.59)

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 ACKNOWLEDGEMENT

For the completion of this project, I would extend my warm gratitude towards those, without
whose help, the completion of this project might not have been possible. Their help, remarks
as well as constructive criticisms kept me on the right track throughout the project. I would
acknowledge my deepest sense of gratitude towards:

Prof.(Dr.) V Vijaykumar, Director, National Law Institute University , Bhopal, for providing
me with the means to make the project.

Our Common Law Method teachers, Prof.(Dr.) Rajiv Kumar Khare who provided me the
opportunity to make the project on the given topic and analyse a judgement.

I am also thankful to the library and computer staff of the University for helping me with the
books and the printing of the project.

Lastly, I am thankful to my parents and friends who gave me the encouragement for the
completion of my project work.

Tanya Shukla

2019 BA LLB59

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TABLE OF CONTENTS

VICARIOUS LIABILITY ......................................................................................................... 7

VICARIOUS LIABILITY OF THE STATE ............................................................................. 8

POSITION IN ENGLAND AND INDIA .................................................................................. 8

POSITION IN ENGLAND- ................................................................................................... 8

POSITION IN INDIA- .............................................................................................................. 9

TORTIOUS CLAIMS AGAINST THE STATE DUE TO NEGLIGENCE OF

GOVERNMENT OFFICIALS ................................................................................................ 10

ACTS DONE IN EXERCISE OF SOVEREIGN POWERS ................................................... 11

1. BaxiAmrik Singh v. Union of India .............................................................................. 11

2. State of Rajasthan v. Vidyawati .................................................................................... 12

ACTS DONE IN EXERCISE OF NON-SOVEREIGN POWERS ......................................... 13

1. Satyawadi Devi v. Union of India................................................................................. 13

2. NilabatiBehera v. State of Orissa .................................................................................. 14

CONSTITUTIONAL TORTS ................................................................................................. 14

PRESENT SITUATION IN INDIA ........................................................................................ 15

IMPORTANT CASE LAWS ................................................................................................... 16

1. Kasturi Lal Ralia Ram Jain v. State of Uttar Pradesh ................................................... 16

2. Achutrao Haribhau Khodwa v. State of Maharashtra ................................................... 17

3. PagadalaNarsimhan v. The Commissioner and Special Officer, Nellore Municipality17

CONCLUSIONS & SUGGESTIONS ..................................................................................... 18

REVIEW OF LITERATURE .................................................................................................. 19

BIBLIOGRAPHY .................................................................................................................... 20

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 SYNOPSIS

STATEMENT OF PROBLEM
The main focus of this project work is to understand the evolution of the concept of vicarious
liability with regards to the state. It aims at discussing about the types of tortious claims that
have been made against the state and how the liability was decided in those cases.

HYPOTHESIS
The liability of state towards private individuals on the violation of any legal right, as a
concept, has largely evolved through the years. It is the duty of the state to provide
compensation to an individual who suffers due to the negligent behaviour of the state
authorities.

METHOD OF STUDY
Doctrinal method of research is used for the preparation of this project.

INTRODUCTION

A tort is an act or omission that gives rise to an injury or harm to another and amounts to a
civil wrong, allowing compensation at the suit of injured parties. The word ‘injury’ here
refers to the violation of any legal right. The primary aims of tort law are the protection of
property rights and individual freedom, to restore the position of the injured party back to as
it was before the commitment of the tort, and also to uphold the principles of ‘justice, equity
and good conscience’. As far as the concept of vicarious liability is concerned, it is not a
distinct tort per se, rather a process by which a person can be held liable for a recognized tort
committed by another person, which is derived from the principle of ‘Respondeat Superior’.
By the principle of vicarious liability, the master is held liable for the negligent acts of his

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servant as it is believed that it is the master on whose directions the servant acts.However, as
far as liability of the state due to any harm caused due to the negligence of the state and its
officials, there was a well established old principle in Anglo-American jurisprudence that the
sovereign cannot be sued without its own consent, which was derived from the ancient
doctrine “Rex Non PotestPeccare”, which meant that the King could do no wrong. But as
time went by, the functions of the state kept on increasing and now the state deals with so
many functions that would possibly haven’t been thought of while deciding upon the state’s
liability. This increase in the domain of the state’s functions started to create more conflict
between the state and the individuals whenever any wrong or negligence was committed on
the part of the authorities of the state. In India, the liability of the state is covered under
Article 300 of Indian Constitution, although no mention is made about the circumstances
under which it can be sued.

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VICARIOUS LIABILITY

Vicarious liability is a doctrine in English tort law which imposes a tortuous liability on a
person on behalf of another’s acts. Here, the person who has to suffer the liability is generally
the employer of the other person; they have a principal-agent, master-servant, guardian-ward
or an employer-employee relationship between them. It is called a no-fault based liability due
to the fact that the master has to suffer the liability and compensate the plaintiff even though
no fault had been committed by him. The complete idea of vicarious liability comes from the
principles of law namely:

1. Respondeat Superior- It means ‘let the master answer’ which holds the master strictly
liable for the wrongful acts of his servant.
2. Quifacitaliumfacit per se- This principle means that ‘he who acts through another
does it himself’which clearly iterates to hold the master liable for the torts committed
by his servant, because it is the master on whose directions the servant works.

The primary conditions to establish vicarious liability are:

1. There must exist a relationship (like that of master-servant) between the persons.
2. A ‘tort’ must be committed.
3. The tort must be committed by the servant in the course of his employment.

The basic reason behind holding the master vicariously liable are:

1. Deep pocket formula- the employer has the monetary ability to pay damages on
account of his servant, owing to the fact that the financial condition of the master is
obviously at a higher pedestal as compared to the servant.
2. If the employer enjoys all the benefits from the servant, he must also pay the damages
on behalf of the servant’s tortuous acts.
3. The master is the person who exercises absolute control and supervision over the
servant.

Therefore, it was decided that the employer must be held liable for the torts committed by his
servant in the course of his employment.

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VICARIOUS LIABILITY OF THE STATE

In early times, the state was not held for any wrongs of its servants or officials because. This
was the rule prevelant in England, where the principle of ‘Rex Non PotestPeccare’ originated.
It was believed that the King was equivalent to God himself and was placed above the law,
and hence he could not commit any wrong. He was given a much higher position and asking
damages from him for the tortious acts of his servants was obviously not justified in any
manner.

POSITION IN ENGLAND AND INDIA

POSITION IN ENGLAND-
In England, the position of the principle ‘The King can do no wrong’(Rex Non
PotestPeccare) at common law was changed by the introduction of The Crown Proceedings
Act, 1947. As time passed, the functions of the State grew by and large and covered a much
larger realm than it did earlier. With the rise in the functions, the tortious claims against the
state also increased immensely. In such a case, denying any kind of compensation to the
injured party merely because the tort was committed by the officials of the state who enjoyed
complete immunity, appeared to be unjust and not in accordance with the principles of
‘justice, equity and good conscience’. Also, it was believed that the court belonged to the
King in the sense that his was the final say in any matter, and therefore, the King could not be
sued in his own court. A judgement of the King’s court in 1234 proclaimed that ‘Our lord, the
King, cannot be summoned or receive a command from anyone’. The only ways by which
redress could be granted against the Crown were by way of petition of right, by suits against
the Attorney General for a declaration, or by actions against by ministers and government
departments which had been incorporated or held liable to suit by state. The position only got
altered after the passing of the Crown Proceedings Act, 1947. This act made changes in
both, the procedure for civil suits by and against the Crown as well as in the law governing
the liabilities of the Crown. It held that the state from then, would be held liable for all
negligent acts of its officials as a master is, for his servant’s acts, for any breach of duties
which a person owes to his servants etc. these provisions were mentioned in Section 2(1) of
the Act. The Crown is hence held liable in respect of Her Majesty’s government to the same

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extent as a private individual of full capacity as well as age. There are, however, restrictions
for the claims that can be made, or in fact, succeed against the Crown. But, in short, the
doctrine ‘The King can do no wrong’ has no place in modern tort law. It no longer meets the
needs of the times, it is unjust and illogical and that it is not just to refuse rightful remedy to
persons who have been injured by the wrong, negligent conduct of the State or its officials.

POSITION IN INDIA-
The position of the liability of state in India is mentioned in article 300 of the constitution of
India. It states that the government of India or the Government of a state may be sued by the
name of Union of India or of the state, as the case may be. However, the mention of the
state’s liability was not made as late as at the time of enforcement of the constitution. The
liability of the state due to the torts committed by its servants was mentioned as early as in
1858 in Section 65 of the Government of India Act, 1858. This description in 1858 came
from Section 32 of the Government of India Act,1915 which in turn originated from Section
176 of the Government of India Act,1935. However, Article 300 is not in itself completely
sufficient to determine vicarious liability of the state since it only mentions that the Union of
India or any particular state can be sued, and not the circumstances under which it can be
sued. At present, the state is held liable for the negligent acts of its servants acting within the
course of their employment. In India, the government has been held liable for the tortious acts
of its servants ever since the East India Company has been in power. The 1858 Act clearly
mentioned that the Secretary of State in Council(which was going to replace East India
Company after 1858) could be sued in the same manner as the East India Company. Now for
this purpose, it is important to understand to understand the position of East India
Companyprior to 1858. One important case in this regard is the case of Peninsularand
Oriental Steam Navigation Company v. Secretary of State for India11 of the Supreme
Court of Calcutta. This case drew a fine and clear distinction between the ambit of sovereign
and non-sovereign functions and in which cases would the East India Company be held
liable. The facts of the case stated that the servant of the plaintiff was passing by the
Kidderpore dockyard in Calcutta(which is a government property) in a horse driven carriage
and due to their negligence, a heavy iron piece fell whose clang frightened the horse. Due to
this, the horse ran away from the iron piece and injured itself. Therefore, due to the injury

1
(1861) 5 Bombay H.C.R. Appeal I, p.1.

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caused, the plaintiff filed a suit against the Secretary of State for India in Council and hence,
the Court laid down the specific functions of the East India Company as a sovereign power
and as a trading company, and described that no action could lie against the state when a tort
was committed while the State was performing a sovereign function. Since, the task here was
non sovereign per se i.e it could be performed by any other private body or individual also,
therefore it was held the State could not escape from liability. Hence, thereafter the liability
of the state was decided in the same manner drawing a distinction between its sovereign and
non-sovereign functions.

TORTIOUS CLAIMS AGAINST THE STATE DUE TO NEGLIGENCE

OF GOVERNMENT OFFICIALS

Serious claims have been made against the government since pre independence times for torts
committed by its servants and officials due to their negligently carrying out certain tasks. The
most common defence pleaded by the government in cases against it is that of sovereign
function. Hence, it became essential for the courts to clarify what type of act would and what
would not constitute a sovereign function. This defence of sovereign function is based on the
very old British common law principle of ‘The King can do no wrong’. Negligence per se,
has two connotations in tort law-

 It can be a mode of committing a tort, for example, negligently committing trespass,

defamation or nuisance.
 As a tort itself i.e. an act that causes a risk of creating some kind of damage to the
other person.

The most famous defence pleaded by the government on being alleged for a tort due to the
negligent working of its servants or officials is that of sovereign immunity. It must be
distinguished however, that which acts fall under sovereign function of the state and which of
them do not.

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ACTS DONE IN EXERCISE OF SOVEREIGN POWERS

A sovereign function is a function which can be performed by the State or its officials only,
and not by any private body or individual. The state is not answerable in any court of law for
a tort committed during the exercise of a sovereign function. The distinction between a
sovereign and a non-sovereign function basically depends on the nature of power and the
manner of exercise of the act. Some examples of sovereign functions of the state are:

 Performing any statutory duty

 Maintaining a military road
 Training of army personnel
 MaintainingNational highways
 Keeping of goods in public Malkhana
 Collecting revenue
 Arrest and detention

Some cases where courts had granted the immunity of sovereign function to the state are as
follows:

1. BaxiAmrik Singh v. Union of India2-

Facts-
On 14th May, 1967, a car suffered an accident with a military truck in AmbalaCantt
and Sepoy Man Singh(who was an army employee) and Amrik Singh (an occupant of
the car) suffered from grave injuries. Hence, he brought an action against the state
asking to be compensated with Rs. 50,000, claiming that the accident was caused due
to the negligent driving of the driver of the truck.
Issue-
The main issue which was to be decided by the Court was whether the task involved
in the present case which was checking the army personnel on duty, fell under the
ambit of sovereign function.
Decision-

2
(1973) 75 P.L.R. 1

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 On hearing of the case, the argument presented by the government of India was that
while the accident was caused, the driver was carrying out a sovereign function of the
state. The Punjab and Haryana high court,therefore, came to the conclusion that
Sepoy Man Singh was assigned the task of checking the army personnel on duty,
which came under the purview of sovereign function, as it could be performed only
by a member of that force who is detained on such duty and also one who is
empowered to discharge that function. Hence, the plaintiff had no claim against the
Union of India. It was established that no claim could lie against the Government if
the official who had been negligent was performing a sovereign function of the State.

2. State of Rajasthan v. Vidyawati3-

Facts-
Lokumal was an employee of the Rajasthan State Government and was employed as a
jeep driver under the collector of Udaipur. In February 1952, he knocked down
JagdishLal, while driving on the road, who suffered multiple injuries and finally
succumbed to death three days later. In accordance to this, Jagishlal’s widow,
vidyawati, brought an action against the state government claiming damages.
Issue-The issue that arose before the Courts in the present case was whether the
negligent driving by the driver which constituted the tort, was under the ambit of
sovereign function of the State.
Decision-
The trial court held that the State could not be held liable in the present case as the
jeep was used specifically for the official works of the collector. Even though the jeep
was not being used for any purpose of the State at the time when the accident took
place, but the Court exempted the State from any liability. However, the State of
Rajasthan appealed against the decision in High Court, which held that the state was
liable like any other private individual, and hence awarded the plaintiff a
compensation of Rs. 15,000. The state government again appealed in the Supreme
Court under Article 300. But the Supreme Court also confirmed the decision of the
High Court and held the State liable because at the time when the accident was
caused, the driver was not in charge of any ‘sovereign function’, and hence the state
had to pay compensation to Jagdishlal’s widow, Vidyawat

3
A.I.R. 1957 Rajasthan 305, confirmed by Supreme Court in the State of Rajasthan v. Vidyawati, A.I.R. 1962 S.C.
933

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ACTS DONE IN EXERCISE OF NON-SOVEREIGN POWERS

Various tortious claims have been made against the State for which the defence of
sovereign function had been pleaded by the Government. However, in many cases,
the Court had not accepted their defence in all situations, particularly after a clear
difference was made between sovereign and non-sovereign functions in cases like P &
O Steam Navigation Company Case. Some examples where a function is non
sovereign are:
 An accident caused by a servant of a state department, who was using the
vehicle for his own personal use at the time when the accident was caused
 Taking ailing children or people to a health care centre
 Famine relief

Some of the cases where it was established that the act of the Union could be performed by
any private individual other than the government too, and was hence a non-sovereign
function are:

1. Satyawadi Devi v. Union of India4 – According to the facts of this case,the

hockey and basketball teams of the air force personnel were carried by an air force
vehicle and meanwhile in the journey, an accident was caused due to the negligent
driving of the driver of the vehicle. As a result of the accident, the plaintiff’s husband
died and she brought a case against the Government of India, which pleaded the
defence of sovereign function. The government said that the practice of such sports
was essential for the army personnel as it kept them fit and healthy, and therefore, it
should be considered as a sovereign act. However, this defence pleaded by the
Government was rejected by the Delhi High Court, saying that this act of carrying the
teams in a vehicle to play matches can be performed by any private individual also,
thus, it cannot come under the purview of sovereign function and the Government had
to pay damages to the wife of the dead.

4
A.I.R. 1967 Delhi 98

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 2. NilabatiBehera v. State of Orissa5-

Facts-
Suman Behera, the son of the petitioner, was taken into police custody for the
investigation in a theft case and dies in the process. His body was found on the
railway track the next day, all bruised and sustaining multiple injuries. From the state
of the dead body, it was clear that the death was caused unnaturally, and was because
of the multifold injuries that were visible on his body. It was, hence, a case of
custodial death, and the petitioner pleaded compensation for the death of her son for
contravention of the right to life, guaranteed to every person under Article 21 of the
Indian Constitution. The Additional Solicitor on behalf of the government, contended
that the dead, Suman Behera had escaped the police station at around 3 a.m. and his
body was found on the railway track the next morning. Therefore, it cannot be
concluded that the death was caused due to the injuries sustained during the police
investigation, rather it was caused because he was knocked down by a train in the
night.

Decision-
The Court rejected the argument presented by the state and said that there was no
reasonable cause to decide against the plaintiff. Also, it was held that all the injuries
on his body could not be caused by a train accident. Hence, a compensation of Rs.
1,50,000 was awarded to the mother of the dead and the Supreme Court also ordered
the Orissa High Court to initiate proceedings against the ones who killed Suman
Behera. Also, the decision in this case ensured that the state could no longer run from
liability in public law.

CONSTITUTIONAL TORTS

Constitutional tort is one that deals with the violation of a fundamental right of an individual.
It is a known duty of the state to protect the fundamental rights of its citizens and maintain

5
(1993) 2 SCC 422

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law and order in the society. A famous case law in the realm of inviting state liability for
consititutional torts is the case of Chairman Railway Board v. Chandrima Das6. In the
YatriNiwas of the Howrah Railway Station, railway employees had gangraped a Bangladeshi
woman Mrs. HnuffaKhatoon, who was a tourist in India, for which Chandrima Das, a lawyer,
had filed a petition against the Govenment. In the proceedings, the Court held that the right to
life under Article 21 of the Indian Consitution was available to every ‘person’ and not just
individuals; even a tourist has the right to protection of his life and personal liberty. The
primary issue raised in the question was whether the act was committed in the course of
employment of the railway employees, to which the courts had given an answer in
affirmative and had directed the Railway authorities to pay compensation to the victim i.e.
Mrs. HanuffaKhatoon.

PRESENT SITUATION IN INDIA

Vicarious liability of the state has always been a complex realm of tort law, because there has
never been as such any hard and fast rule to establish liability of the state and neither does the
Constitution mention any kind of circumstances under which the Union of India can be sued.
No laws have been made under clause (1) of Article 300 of the Constitution neither by the
state legislatures nor by the Parliament. Hence, the present situation in India holds that if such
a suit can be filed against the corresponding province, then the state can be held liable. The
situation in India, hence, is very uncertain. In many cases, the Supreme Court has granted
compensation as an additional remedy or relief to the injured party while it was exercising its
jurisdiction under the writs i.e. Article 32 of the Indian Constitution. The Law Commission of
India had recommended in its first report ‘Liability of State in Tort’ that a legislation be made
regarding State liability, like in England. A bill entitled ‘The government Liability(Liability
in tort) Bill, 1967 was also introduced in the Lok Sabha, according to the report. This bill
defines the government’s liability towards third parties for its servants’ wrongs or negligent
acts. However, it is unfortunate that the recommendations made by the Law Commission way
back in 1956 and the suggestions made by the Supreme Court have yet not been given effect
to. This disappointing state of affairs is not in consonance with the principles of social justice
in a welfare

6
A.I.R. 2000 S.C. 988

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IMPORTANT CASE LAWS

1. Kasturi Lal Ralia Ram Jain v. State of Uttar Pradesh7-

Facts-

KasturilalRalia Ram Jain was a firm in Amritsar, which used to deal in bullion and
various other goods. On 20th September, 1947, one of the partners of the firm, Ralia
Ram arrived at Meerut at about midnight by the Frontier Mail. His purpose of going
to meerut was to sell gold, silver and other goods in the market. While he was in
meerut, three police constables found him and took him into custody and then, he was
detained in the Kotwali Police Station where all his belongings containing heavy
quantities of gold and silver were seized. On the next day, I.e. 21st September, Ralia
Ram was released from police custody, and his silver was returned to him after a few
days. Ralia ram made several appeals to the police officials to return the gold back to
him. But since his requests were to no avail. He filed a petition against the police
department claiming that either his gold be returned to him, if not, the amount of the
gold be paid to him.

Decision-

It was found that the gold belonging to Ralia Ram, was kept in the custody of the
Head Constable or the incharge of the Malkhana, Mohammad Amir. The constable
misappropriated the gold and some cash from the Malkhana and fled to Pakistan on
17th October, 1947. It was argued by the respondent that the police officials were not
negligent in their work, and even if they were, the state would not be liable to pay
damages to the plaintiff.

The courts held that the police officials were, no doubt negligent in handling the gold
belonging to the plaintiff. After it was seized, it was not even weighed by them. The
famous case of Peninsular and Oriental steam Navigation Company v. The Secretary
of State for India2 was cited by the court as an authority in the case. It was stated that
the power to arrest a person or search or seize his property are powers that are
conferred on the special officers by statute. Hence, it was clear that the act of
negligently handling the gold was done by the police officials during the course of

7
A.I.R. 1965 S.C. 1039

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 their employment. But the defence of sovereign function was allowed to the state of
U.P. on the grounds that this special power authorized to the specific officer could not
be exercised by any other private individual, and therefore, it fell under the ambit of a
sovereign function. Also, it was stated by the court that the officers were discharging
their statutory powers. It must, however, be also noted that the Supreme Court, after
this case, developed a principle that the defence of sovereign immunity cannot be
pleaded by the state when there has been any violation of Article 21, as it is an
example of a constitutional wrong, a public law remedy.

2. Achutrao Haribhau Khodwa v. State of Maharashtra8-

Facts-
While performing a sterilization operation on a lady, a doctor of a government
hospital accidently left a mop inside the abdomen of the patient, which was found
only after the lady felt severe pain in her abdomen after the operation was over. As a
result of this, the lady developed peritonitis, which is a disease caused by the
inflammation of the peritoneum, and finally succumbed to death.
Decision-
The doctor had pleaded that there was a power supply cut during the time of the
operation, therefore, it was due to a mistake that the mop was left behind in her
abdomen. The courts replied that it was all the more important for him as a doctor to
pay more attention and care to the work if there was no power supply. This is a
leading case in the area of medical negligence. The hospital had also pleaded the
defence of sovereign function, to which the Court had said that running a hospital was
not a sovereign function, and hence, the hospital was held liable for the negligence of
the doctor in carrying out the operation.

3. PagadalaNarsimhan v. The Commissioner and Special Officer, Nellore

Municipality9-
Facts-
A bus belonging to the plaintiff had been parked by him wrongly, which caused a lot
of obstruction to the common traffic. Because of creating inconvenience to the public,
8
1996 A.C.J. 505(S.C.)
9
A.I.R. 1994 A.P. 21

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 the bus was removed from that point by the traffic police with the help of the
municipal office employees.
Decision-
It was decided that the police was not negligent in their work, in fact, their act was
completely justified and carrying out the duties by the police officials came under the
purview of sovereign function, and therefore, the State could not be held liable for the
acts of the police officials.

CONCLUSIONS & SUGGESTIONS

In early times, the doctrine of ‘The King can do no wrong’ was prevelant in UK, from where
it emerged as the King was considered above all individuals back then and it was believed
that the King was the one who owned the Courts. Therefore, he was not held liable and
enjoyed absolute immunity from any tortious proceedings. But soon it was realized that this
principle was very much against the basic principles of law and justice and it was necessary
that the party injured by the wrongful conduct of the state officials be compensated. Hence,
the concept of vicarious liability of the state came into play as tortious claims in negligence
gradually increased in number with the passage of time. The present situation of vicarious
liability of state is very complex in India. The state is generally held liable for the negligent
conduct of its servants and officials, unless the state can prove in the court that the work
which was being done negligently was a sovereign function of the state and could be done
only by the authorized officials, and not any private body or individual. It is however, the
discretion of the courts to decide whether the said function falls under the ambit of a
sovereign function of the state.

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REVIEW OF LITERATURE

1. Law of Torts by Dr. R.K. Bangia-

For the preparation of this project, I have referred to the well established tort book by
Dr. R.K. Bangia. This book on the Law of Torts deals with all concepts of law of
torts, from the smallest to the largest ones. A comprehensive reading of this book is
enough to verse the reader with the minutest of principles of the law of torts. Also, the
case laws have been described in the shortest and most useful form possible in this
book, which makes it all the more easier to comprehend, unlike lengthy court
judgements.

2. Tort Law by Catherine Eliott and Frances Quinn-

This book was very useful for me to understand the basic legal principles applied in
various cases. It includes discussion of problems with the current law, thus helping to
develop an analytical approach. It also relates the legal principles of tort law with the
present situation in the society, making the tort law relevant and interesting to study.

3. Law of Torts by Ramaswamy Iyer-

This book explains the various concepts in the field of law of torts in modern India. It
critically analyses the nuances of this branch of law and beautifully explains
precedents and case laws. Various famous judgements, both Indian and foreign, which
has been really helpful for me in making this project.

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BIBLIOGRAPHY

For the completion of this project, I have referred to the following sources:-

1. www.wikipedia.com
2. www.legaldictionary.net
3. www.toppr.com
4. www.investopedia.com
5. www.legalservicesindia.com
6. www.britannica.com

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