State of Rajasthan v. Mrs. Vidyawati 1962 (Case Summary)

This landmark case expanded the scope of state liability in tort law, establishing that the government can be held liable for the negligent acts of its employees when performed in the course of non-sovereign functions.

Facts of State of Rajasthan v Mrs. Vidyawati

1. A government vehicle driven by a temporary employee of the State of Rajasthan hit and fatally injured Vidyawati’s husband due to the driver’s negligence.
2. The jeep was being driven back from a repair shop to the residence of the Collector of Udaipur.
3. Mrs. Vidyawati, the widow, filed a suit against the driver and the State of Rajasthan, seeking compensation for her husband’s death, claiming the driver’s negligence occurred during the course of employment.

Issues framed

1. Whether the state is vicariously liable for the negligent acts of its employees when such acts occur during the performance of non-sovereign functions?
2. Whether the immunity from tortious liability be claimed by the state in such circumstances?

Subordinate Court Judgment

The trial court ruled in favor of Mrs. Vidyawati, holding the State of Rajasthan liable for the driver’s negligence. It concluded that the driver’s actions were performed in the course of his employment, and the state could not claim immunity because maintaining government vehicles is a non-sovereign function. The trial court awarded compensation to Mrs. Vidyawati for the loss caused by the negligence of the state’s employee.

The Hon’ble Rajasthan High Court while upholding the trial court’s judgment observed that allowing the defence of sovereign immunity in such cases would be unjust, as it would deprive citizens of their rightful compensation for harm caused by government employees. 

The case then was appealed to the Supreme Court of India.

Judgment of State of Rajasthan v Mrs. Vidyawati 

The Supreme Court analyzed the principles of vicarious liability and sovereign immunity under tort law. 

The Supreme court emphasized that the doctrine of sovereign immunity cannot be applied universally to shield the state from liability in all instances. It held that while the state enjoys immunity for acts performed in sovereign functions, it is liable for torts committed during non-sovereign. The negligent act of the driver, performed during the routine maintenance of a government vehicle, was deemed a non-sovereign function.

The Supreme Court dismissed the appeal affirming the High Court’s decision, to award ₹15,000 as compensation to the plaintiffs. The court held that the State of Rajasthan was vicariously liable for the negligent act of its employee, ruling in favor of Mrs. Vidyawati.