Essence of the Principle:
The doctrine applies when:
The accident is of a kind that ordinarily does not occur in the absence of negligence.
The instrumentality causing harm was under the exclusive control of the defendant.
The plaintiff did not contribute to the cause of the injury.
When these conditions are met, the burden of proof shifts to the defendant to explain how the accident occurred without negligence on their part.
Key Features:
It is a rule of evidence, not of substantive law.
It allows the court to infer negligence based on circumstantial facts.
It applies in cases where direct evidence is unavailable, but the event’s nature points to fault.
Landmark Case Law:
Scott v. London and St. Katherine Docks Co. (1865)
A dockworker was injured by sacks falling from a warehouse. The court held that such an accident doesn’t happen without negligence, and thus, res ipsa loquitur applied.
Municipal Corporation of Delhi v. Subhagwanti (1966)
A clock tower collapsed, killing several people. The Supreme Court of India held that such structures don’t collapse without negligence, invoking the doctrine.
Application in India:
Indian courts have applied the principle in cases involving medical negligence, defective infrastructure, and industrial accidents, provided the conditions are met.
Conclusion:
Res ipsa loquitur is a powerful tool that helps plaintiffs establish a prima facie case of negligence in situations where the facts themselves point to negligence, thus facilitating justice in the absence of direct evidence. However, its application is cautious and case-specific.
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