MEANING OF NEGLIGENCE AND ITS APPLICATION IN

PROFESSIONS

LAW OF TORTS PROJECT

SUBMITTED BY: SUBMITTED TO:

NAME: AAPIR AKSHANSH GAURAV DR. SUBIR KUMAR

SEMESTER: III ASSISTANT PROFESSOR

SECTION: B

ROLL NO.: 1273

NATIONAL UNIVERSITY OF STUDY AND RESEARCH

IN LAW, RANCHI

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 TABLE OF CONTENTS

1. INTRODUCTION………………………………………………………………………3
2. ESSENTIALS FOR TORT OF NEGLIGENCE……………………………………...5
3. NEGLIGENCE IN PROFESSIONS…………………………………………………..10
4. NEGLIGENCE IN MEDICAL PROFESSION………………………………………11
5. NEGLIGENCE IN LEGAL PROFESSION………………………………………….13
6. NEGLIGENCE BY MANUFACTURERS……………………………………………15
7. CONCLUSION…………………………………………………………………………18

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 INTRODUCTION

Negligence of Torts is when you fail to act in accordance with an obligation. It can happen
either because you didn't use due care or because you failed to do something which you should
have done. It is an unintentional act that causes harm to someone else. The tort itself has been
defined as an unintentional wrongful act that causes injury to another person.

In order for a duty to exist, there must be some kind of law imposing obligations on one or more
people. If no such burden exists, then negligence is an unlawful action and cannot result in
liability. Meaning, if there's nothing forcing a party (whether public or private) to abide by any
certain laws, it will be impossible to sue them for their failure to uphold those duties. This does
not mean you can't file charges against them whatsoever, only that money damages won't be
granted because they failed to do so. You could instead take legal action against them with
regards to another matter i.e., breach of contract.

If there was some sort of legal obligation on the part of someone else (either public or private)
and they failed in their duties towards you, then you could potentially bring suit against them
based upon your claim that they were negligent when performing those duties towards you.
However, this would only occur if your claim was based upon what happened during
performance by another person's act/failure/omission/etc., rather than something completely
separated from whatever occurred during performance but which did not directly relate back to
what happened during performance e.g., personal injury resulting from medical malpractice. In
such case, you would still have to prove that the act/failure/omission was a proximate cause of
your injury, and then you could sue them for damages.

The torts are not defined under the Indian law and it has been left to be decided on a case-to-case
basis which requires an analysis of each incident and its surrounding circumstances. In order to
establish negligence as a cause of action for damages, two elements must be satisfied: (1) there
must have been a duty owed by one party to another; and (2) that duty must have been breached
by the other party. It is necessary for both parties to prove their respective roles in such incidents
and also show that they had acted negligently or carelessly in performing their duties towards
others.

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Negligence is not a strict liability of tort. To establish this, the plaintiff must prove that there was
an obligation between them and that they were responsible for breaching it. The duty owed by
one party to another could be either explicit or implicit depending on what the situation might
call for. If there is an explicit duty, then failure to comply with those duties in accordance with
the contract terms would make them exempt from any claims made against them. However, if
there is no such contractual obligation then a duty may still exist but this will be based upon what
would be considered reasonable behavior in similar situations. This means that even though there
may not be any express contractual duty, if both parties behaved reasonably, they would owe
each other some form of duty which can give rise to a cause of action for damages against them.
Even where an act has been performed negligently, it does not necessarily follow that the person
who performs such act should also suffer loss as well as damage caused by his or her negligent
performance of duties towards others; however, in certain cases such losses can become
recoverable under certain circumstances provided they are foreseeable at the time when such acts
were performed and could have been prevented by due care on part of those performing them.

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 ESSENTIALS FOR TORT OF NEGLIGENCE

To commit the tort of negligence, there are mainly five main requirements that must be met. If
any one or more requirement is missing then it cannot be said to be negligent action:

1. Duty of care

Duty of care is a responsibility that every person owes to other people during the process
of engaging in an act. This duty is applicable to all actions, but it becomes legal when
someone commits negligence. It cannot be morally wrong, unethical or based on religion,
only lawful and justifiable. For a case to fall under negligence law, there needs to have
been fault committed by the defendant (person who was negligent). If this took place,
then they will be liable for damages caused by their own mistakes. Negligence law falls
under tort law and is its branch much like how theft would qualify as larceny while
larceny falls under robbery which falls under criminal laws.

In the case of Dullabhji S. Sanghani And Anna . v The G.I.P. Ry. Co.1, a the defendant
was found liable for negligence. The plaintiff, who had been injured when he fell from a
train as the door was open without having a guard on duty at that time, won the case
against the railway company and was awarded compensation for his injuries. This
suggests that if one of these contributing factors to an accident or injury is due to
negligence, then liability will be imposed upon them by law courts and they will have to
compensate their victims accordingly.

In the case of Qamar Jahan & Anr. v Dr. Nisar Ahmed Tyagi & Ors. 2, the defendant was
a nurse who negligently failed to check on her patient for signs of infection and thus caused him
to suffer from a skin disease that required surgery which cost him over 10,000 rupees in medical
bills. The defendant was held liable and ordered to pay damages as she had been negligent by not
checking on her patient's condition properly

1
Dullabhji S. Sanghani And Anna v The G.I.P. Ry. Co., (1910) 12 BOMLR 73
2
Qamar Jahan & Anr. vs Dr. Nisar Ahmed Tyagi & Ors,(2019)

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 2. The duty must be owed to the plaintiff

Duty arises when the law recognizes a relationship between defendant and plaintiff. If a
duty of care exists, one must establish whether this was breached. This is usually
determined by judge. The tort of negligence is a cause of action that arises when defendant
breaches his/her duty to plaintiff and causes harm or damage (or from lack thereof).
Plaintiff can sue for damages related to any loss, injury, or damage caused by Defendant's
breach. A claim will only succeed if there is a connection between Defendant's conduct
and Plaintiff's loss - if it could be reasonably foreseen that Defendant would act
negligently towards another person and owed him/her duties because of it.

In the case of Kite v. Napp3, the defendant was found to have been negligent in that he left
his dog unattended on a leash and this resulted in injury to another person, who had to undergo
surgery as a result of being bitten by the dog. The Court held that there was no duty owed by the
owner of the dog towards his neighbor because he did not owe him any care or attention nor did
he owe him any protection from animals which were dangerous. The defendant's failure to take
reasonable steps for others' safety is considered negligence under these circumstances.

3. Breach Of Duty To Take Care

It is not enough for a plaintiff to show that the defendant owed him or her a duty of care,
instead, he or she must also prove that the defendant acted negligently when fulfilling this
responsibility. An individual acts negligently when they fail to exercise reasonable care
while performing their task. A person can show a duty exists if they point to an instance
where the other party has acted. They need only demonstrate that they had failed,
neglected or omitted one specific act which should have been done under certain
circumstances. It doesn't matter if it was intentional or not.

3
Kite v Napp, (1982)

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 In the case of Municipal Corporation of Delhi v. Subhagwanti 4, very old clock tower
situated right in the middle of a crowded area of Chandni Chowk suddenly collapsed
thereby causing the death of many people. The clock tower was 80 years old although it
should have lasted for only 40-45 years at most. The clock tower was under the control of
The Municipal Corporation of Delhi and they had a duty to care for its citizens' welfare
but by neglecting to maintain the clock tower, they had ignored this responsibility, which
resulted in many people's deaths. The Court ruled that the Municipal Corporation had an
obligation to maintain the clock tower since it was built for the public; yet, when they
failed to do so, it led to people dying as a result. However, in order for them to win this
case against them, they must show beyond a reasonable doubt with certainty that their
neglect occurred through negligence on their part and not because of structural defect.

In the case of Ramesh Kumar Nayak v Union of India 5, the defendant suffered injuries
after a post office wall collapsed from neglect. The postal agency was ordered to
compensate for damages done due to their careless maintenance practices. So long as a
negligent actor takes part in an activity that carries risk, there will be some duty for them
to take reasonable care so as not to cause such harm or damage; this is called the duty of
care. For example, if one drives without looking out for pedestrians crossing the road-
even though it may technically be illegal - there would still exist a degree of care
associated with causing injury because one had been negligent. This theory means that
people may make mistakes but still have obligations which depend on how serious it is.

4. Proximate Cause

Proximate cause means the primary cause, or the one that the law recognizes as being
such. It isn't always the first event in a series of events leading up to an injury, nor will it
always be the last one before someone suffers harm. A defense attorney in a negligence
suit cannot be held accountable for all damages, even if they are foreseeable consequences
of his client's actions; they are only responsible for those that they could have foreseen
themselves through their own behavior. The proximate cause of an injury is what the law

4
Municipal Corporation Of Delhi vs Subhagwanti & Others, 1966 AIR 1750, 1966 SCR (3) 649
5
Ramesh Kumar Nayak vs Union Of India, 1995 ACJ 443, AIR 1994 Ori 279, 1994 I OLR 536

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 classifies as its main and original reason; though often times plaintiffs cannot show
conclusively that a certain person's negligence was solely or even partially liable for their
pain, yet they can receive financial compensation when there has been evidence showing
at least one other negligent party who has contributed to their suffering.

In the case of Palsgraf vs. Long Island Railroad Company 6, an incident occurred whereby
Mr. Palsgraf attempted to board a train after hurriedly running for it and carrying a bag
containing items along with him, all this despite having just suffered from chest pains. As
he started up the steps, two employees on either side approached and grabbed his arms in
an attempt to help him onto the car. This resulted in dropping his belongings onto the
tracks below; upon contact with them, they exploded due to what was found out later to be
fireworks within his bag. Mrs. Palsgraf filed suit against the railway employees for her
injury; but because there was no direct causation between employees injury actions and
her injury i e, there were other alternatives besides grabbing Mr. Palsgraf that could've
prevented Mrs. Palsgraf being injured, she did not receive relief. The court in this case
ruled that the employees of the railway company had no duty to warn Ms. Palsgraf about
the package she was carrying or else risk liability for her injury. They also affirmed that
even if they had been made aware of what she was carrying, it wouldn't have affected their
actions because they were under no obligation to protect each and every person on board -
as long as there were no foreseeable risks to them.

5. Consequential Harm To The Plaintiff

Proving that the defendant failed to exercise reasonable care is not enough. It should also
be proven that the failure of the defendant to exercise reasonable care resulted in damages
to the plaintiff who had a legal right against which his conduct could have been measured
with respect for its consequences on his person or property . There is no single test for
determining whether a duty of care exists. The question is one of law, and it will be
determined by reference both to general principles applicable in tort cases as well as by
reference specifically made thereto in any particular case. The plaintiff must prove that the
defendant owed a duty of care. The plaintiff must show that the defendant owed a duty of

6
Palsgraf v. Long Island Railroad Co, 248 N.Y. 339; 162 N.E. 99; 1928 N.Y. LEXIS 1269; 59 A.L.R. 1253

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 care, and that this duty was breached. The court will look at all the circumstances to
determine if there was a duty owed by the defendant to plaintiff.

In the case of Jang Bahadur v. Sunder Lal Mandal7, the defendant of the bus was driving
the bus with recklessly and negligently on the wrong side of the road. One of the
pedestrian also raised his hand to signal the bus to stop so as to protect the horse of the
plaintiff who was standing on the road. But the driver continued with his negligent driving
due to which the horse was seriously injured. The court held that since driver was driving
negligently on the wrong side of the road, he would held liable and had to pay Rs. 1200/-
for the damages to the plaintiff since he had to suffer the loss and harm by his act.

7
Jang Bahadur Singh vs Sunder Lal Mandal, AIR 1962 Pat 258

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 NEGLIGENCE IN PROFESSIONS

Professional negligence is a complex area of law. It occurs when an individual fails to

meet the requirements for their profession. Before defending against claims involving
allegations of professional negligence, it's best to seek legal counsel for advice in every
case. Professional negligence is quite serious and it can lead to severe injuries. These
kinds of injuries would typically require medical attention, but may not be received from
the negligent doctor or hospital due to lack of care. If a victim has been harmed due to
professional negligence, they may file charges against said negligent professionals.

In India, professional negligence cases are all too common. Most times its a question of
doctor-patient relationship gone wrong. Doctors who hurt their patients will often try to
escape accountability for their harmful acts by claiming that they didn't know the patient's
medical history or because they were being pressured by another doctor - but there are
countless instances when these defenses crumble and the victim has the evidence needed
to dispute them in court proceedings.

In such cases, it is extremely difficult for a patient who suffers from injury or illness and
his/her family members to receive justice because doctors refuse to accept responsibility
for their actions and do anything in their power not to allow anyone else of taking action
against them. When accused of wrongdoing, they tend to blame other doctors if they
themselves are found responsible but when asked why they never informed others about
these problems-then this response is I was too busy. With enough proof provided by the
victims in court proceedings, false accusations made by these people often do not hold up
in the end. Also there are cases when negligence on the part of manufacturer whic lead to
harm done. In such cases it is difficult for victims, their families or dependents to get
justice because these people try to shift responsibility and say they don't know anything
about safety measures. Also due to negligence from lawyers, the victims or their family
members were unable to obtain justice for such cases.

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 NEGLIGENCE IN MEDICAL PROFESSION

Negligence can be seen in doctors who fail to do what they are supposed to do, or did
something wrong; such as leaving a sponge inside of you during surgery. When this
happens, the victim has grounds for suing the physician for damages. When a patient
comes to the doctor for care, an implied duty of care arises on the part of doctor. This
duty of care is a legal obligation owed by the doctor to his patient and mandates that he
exercises reasonable skill and competence while performing his duties. Compensation
will be provided when medical errors occur that result in damages against this.

The doctor owes following duty of care towards his patient:

1. A duty to decide whether or not to take the case

2. A duty of care in deciding what treatments to give
3. A duty of care in the administration of the treatment

When a doctor breaches any duty, the patient can take legal action. The preference to
choose what type of treatment they want is available for doctors, so if one chooses they
are obligated to follow through. If there's an emergency then the hospital has to provide
reasonable medical care.

In the case of R.P.Sharma v. State of Rajasthan8, Plaintiff Mrs. Kamla Sharma had
surgery to remove her gallstones in SMS Hospital, Jaipur. The doctor then recommended
a blood transfusion. One pint was done and then another was attempted but with an
unfamiliar type. Eventually she lost sight after this third transfusion and later died
because of medical malpractice committed by staff at the hospital. Defendant is
vicariously liable for these offenses which caused injury or death due to personal neglect.

In the case of Aparna Dutta v. Apollo Hospital Enterprises Ltd 9, the plaintiff was living
with her husband in Saudi Arabia when she developed some gynecological problems and
needed surgery due to which they moved back to India. Despite having an operation at

8
R.P. Sharma vs State Of Rajasthan, 2003 ACJ 2093, AIR 2002 Raj 104, 2002 (2) WLC 345, 2002 (4) WLN 361
9
Arpana Dutta vs Apollo Hospitals Enterprises, 2002 ACJ 954, AIR 2000 Mad 340, (2000) IIMLJ 772

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first, it had been forgotten that an abdominal pack had been left behind which caused
severe pain and repeated surgeries needed to remove it. So after much deliberation, the
maxim res ipsa loquitor applied, holding both the surgeon and hospital responsible for
this failure.

In all the cases listed above, it is clear that either the doctor or the nurse or one of the
other hospital officials were negligent. A doctor is not held accountable for every act that
puts a patient at risk but instead they should be held accountable when they have been
negligent. It requires an even higher level of care from specialists who work in hospitals
because they have more experience with their jobs than nurses and doctors who are just
starting out and also it is expected by a professional to have proper knowledge and skill
of his profession.

In other words, this court decision shows us an important lesson about how easy it is to
prove product liability under certain conditions like negligence on behalf of
manufacturers and knowing what precautions they could have taken. In conclusion we
can say that these cases show us how easy it is for someone who has suffered injury or
loss as a result of neglecting their duty toward others through being careless with safety
measures they took themselves by ignoring them just because they were confident
enough in their products, they thought there was no need for them to do anything else
than selling their products without caring about its safety or harmful effects on humans.
In other words, these cases show us the importance of doing our own part when dealing
with dangerous things such as chemicals to prevent accidents from happening which may
lead into serious consequences later on.

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 NEGLIGENCE IN LEGAL PROFESSION

A lawyer is liable for negligence when he fails to take steps necessary to ensure that the
cause is properly administered or conducted. It may include such things as failing to
obtain an order from the court appointing any person as guardian or failing to attend at
trial on time, failure to appear at trial without justifiable excuse, neglecting or refusing
instructions from clients, neglecting or refusing instructions from courts, improper
conduct during trials before juries, judges and other legal bodies etc, . Failure in giving
notice of intention not appearing at trial etc., which results in loss of cause. In case of a
lawyer's negligence in the preparation of his pleadings, he will be held liable for damages
and also if a lawyer fails to apply for leave to appeal within the prescribed period, then he
is negligent and can be sued by his client.

The lawyer owes following duty towards their clients:

1) To act with reasonable diligence and competence

2) To inform his client about the nature of his work, the fees he charges and about any
other matter that is material to the transaction for which he is acting as counsel

3) To keep in mind all circumstances affecting the case, including those not within his
knowledge or control. If a lawyer fails to do so, then it amounts to negligence on part of
him.

The duty also includes ensuring that there are no conflicts between himself and another
party who might be able to influence him in favour of one side over another. This may
include such things as failing to disclose facts relevant to an issue or proceeding before a
court etc., which result in loss of cause. In case a lawyer's negligence results into an
adverse decision by the court against his client, then he will have been negligent and can
be sued by his client.

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 In the case of M. Veerappa v Evelyn Squeria10, the plaintiff was a businessman whose
eviction notice for his business premises was passed by Karnataka High Court. For this
regard he had approached a lawyer to fight his case. During the proceedings the plaintiff
died after which the lawyer opposed the application and stopped fighting the case stating
that the injuries are sustained by the plaintiff after his death his case has become
unpleasant. So his son then filed suit against the lawyer for refund of court fees,
reimbursement of fees to engage another lawyer and also compensation for his negligent
act as a lawyer toward his client. The Supreme Court contend that a death plaintiff shall
not the suit to abate if the right to sue survives and therefore held liable the lawyer for his
negligent behaviour towards the plaintiff.

In the case of Manjit Kaur v Deol Bus Service11, the husband of the plaintiff was died in
an accident with bus. For getting compensation for this act she approached a lawyer. Her
lawyer told her that he will go through the proceedings and there is no requirement for
her to come. After some time plaintiff come to know that her case has been dismissed in
the court since her lawyer failed to appear on behalf of her. The Court taking into account
the unconditional apology offered by the lawyer in such a negligent way, held liable for
his negligent behaviour towards his profession and client, compensation of Rs. 1000 for
re-hearing of the case through other lawyer.

From the above cases, it is clear that liability of the lawyer is not only limited to his
negligence in relation to his client, but also includes any failure on his part towards the
court proceedings.

10
M Veerappa v Evelyn Sequeira, 1988 AIR 506, 1988 SCR (2) 606
11
Manjit Kaur v Deol Bus Service, (1990) ACC 517, AIR 1989 P H 183

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 NEGLIGENCE BY MANUFACTURERS

Manufacturers have an obligation to produce safe products, both while they are still being
created and after they've been packaged up and put on the shelves. Manufacturers owe this duty
of care to all buyers who may purchase their product, but it doesn't mean that they are liable for
any injuries or damages caused by a defective product. If something is dangerous like if it was
defective enough, then whoever can reasonably foreseeably be hurt by the defect in the product
could have a claim against that manufacturer. And so, because of this no-privity-of-contract
thingy, which states you can only sue another person involved in a contract directly;
manufacturers don't need to worry about being sued over damages incurred from faulty parts as
suppliers and distributors are also responsible too for example if a person have damaged his own
car due to some defect in the manufacturing process , then he can sue the manufacturer as well as
other people who supplied parts of the car like tyres, etc . So , negligence law is a very important
part of tort law and helps in determining liability between different parties involved in an
accident case.

The negligence of manufacture can be through various methods including:

1) Manufacturing negligence can happen during the production process when there is a lack
of diligence involved and this results in making defective products.
2) Designing negligence can happen when not enough time or effort has been put into
researching the design carefully, such as forgetting to conduct thorough testing.
3) Negligence during testing can happen when scientists are careless while running
experiments or they don't do them correctly.
4) When hazards are not warned about properly then you're neglecting your duty of care
because you know there's a risk but refuse to take action for fear it will make things
worse, example recalling dangerous products.

Product liability claims can be difficult because the person who designed or manufactured
the product is usually deemed liable for failing to exercise reasonable care which led to
injury. This means that if someone wants to bring up a claim against a manufacturer, they
would have to prove that there was negligence involved and then contact an attorney

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 specializing in personal injury law. However, there are some exceptions where people who
received injuries from certain defects might not need proof of negligent behavior at all
because they qualify under res ipsa loquitur (Latin for the thing speaks for itself). If someone
had sustained an injury due to faulty design or manufacturing procedures and showed how
those actions were likely negligent, then it would make things much easier for them to prove
negligence in part of manufacturer so as to held them liable.

In the case of Donoghue v. Stevenson12, which is famously known as ‘The Snail in Ginger
Beer case’, where the plaintiff was served a ginger beer bottle by a friend who had taken it
from a grocery store. The plaintiff consumed most of the drink while unaware that inside the
opaque green glass container was decomposed snail remains. Filled with nausea and acute
gastroenteritis, due to his lack of knowledge, the plaintiff was able to prove that the
defendant was liable for the injuries and losses. The court held that the defendant should have
taken greater care in the manufacturing of the bottle, which would have prevented its
contents from being decomposed. This is an example of how a product liability can be
proven by showing negligence on behalf of manufacturer and also proving how it is possible
to avoid this kind of injury or loss.

In other words, this court decision shows us an important lesson about how easy it can be to
prove product liability under certain conditions like negligence on behalf of manufacturers
and knowing what precautions they could have done.

In the case of Ambala D. Bhatt v State of Gujarat, 13 the defendants were the manufacturers of
drugs in Chemical Industries Ltd. Baroda. These drugs were been consumed by the plaintiff
and after consuming them, suddenly his condition got very much more severe and got death.
The manufacturers were negligently manufacturing a solution of glucose in normal saline
Batch since only 0.000005% of lead could be used for producing a drug but they used more
than that which made it a harmful chemical which leads to the death of the person and many
other persons who died after consuming the drug, since it’s hazardous and the manufacturers
were also neglecting their duty of care to prepare it taking every precautionary measure.

12
Donoghue v Stevenson, (1932) AC 562
13
Ambala D. Bhatt v State of Gujarat, AIR 1972 SC 1150, 1972 CriLJ 727, (1972) 3 SCC 525

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Through the cases we see that the manufacturers of the drug were negligent in
manufacturing it and they could have avoided this kind of injury. by taking proper care,
but they didn’t take any precautionary measures and in the end it resulted in death of
many people.

The manufacturers were also negligent since they should have taken every precautionary
measure so that this kind of accident doesn't happen. The negligence on behalf of the
manufacturer is proven by not only the fact that they did not take precautions to avoid
such an injury or loss, but also because they knew about this danger and still neglected
their duty to take all necessary precautions. This shows us how easy it can be for a person
who has been injured due to negligence on behalf of the manufacturers and knowing what
precautions could have been done.

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 CONCLUSION

Negligence is such a frequent occurrence in the world of professionals and has impacted
many people. It is important for these professionals to take care of their work, as well as
keep their clients safe from any damage caused by mistakes made during their profession.
Some professionals don't accept responsibility for their own failures and not all clients
who have suffered due to the mistakes of other professionals will ever receive justice
which means that more laws need to be put in place pertaining specifically to this
negligence. As doctors are expected to know the law and dealt with it when needed, since
they typically learn about it in school while they're learning medicine. They operate
differently than most people. However, there isn't always a chance for success in
everything. The awareness of patients' rights has grown over time which may affect
doctors negatively due to possible lawsuits for crimes or civil suits if someone wasn't
treated well enough. Other professions deal with this too, just less often but mostly due to
their experience and different level of concern for human life than those who practice
medicine. Also when the professionals are being held accountable for their actions, it
protects the customer, client, and patient from unfair treatment and encourages them to
act responsibly. Oftentimes, when the negligent party is punished under the law they tend
to become more efficient in order for such mistakes not to happen again. In law,
professionals such as doctors, manufacturers, lawyers, etc. are considered negligent if
they use their specific skill incorrectly or if they do not use it at all. This means that these
skilled professionals can be held liable for negligence in two cases: when they proclaim
to have knowledge of something but don't possess it or when they do possess the needed
skills but use them improperly.

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