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Joint Tortfeasors

Chapter Fifty

Syllabus topic 2.5, "Joint Tort-Feasors, Nervous Shock and Malicious abuse of Legal Process."

Pages 203 to 206 of 434

In one line

Where two or more people are responsible for the same damage, the injured person may recover the whole of it from any one of them.

In the wording a student can write in an exam: persons are joint tortfeasors where they act in furtherance of a common design, where one is vicariously liable for the tort of the other, or where they breach a joint duty; their liability to the plaintiff is joint and several, so that he may sue any one or all of them and recover the whole of his damages from any one, subject to satisfaction only once, and the rule preventing contribution between wrongdoers has been abandoned so that a tortfeasor who pays may recover a share from the others.

Who is a joint tortfeasor

Agency and vicarious liability. A master and his servant, a principal and his agent, and partners in a firm, where the wrong is committed in the course of the employment, agency or business.

Common design. Two or more persons acting in concert in pursuance of a common purpose, so that the act of one is the act of all.

Breach of a joint duty. Where two persons owe a duty together and both fail, for example joint owners of a building that collapses.

Joint against independent tortfeasors, and composite negligence

Joint tortfeasorsIndependent tortfeasors causing the same damage
RelationshipCommon design, agency, or a joint dutyNone; they act independently
The tortOne tort committed by allSeparate torts producing one damage
Liability to the plaintiffJoint and severalEach liable for the damage he caused, and jointly where the damage is indivisible
ExampleTwo partners publishing a libelTwo drivers colliding and injuring a pedestrian

Composite negligence is the Indian expression for the second situation where the injury is indivisible, and the leading authority is Indian.

Facts. Khenyei v. New India Assurance Co. Ltd, (2015) 9 SCC 273, decided on 7 May 2015. A claimant was injured in an accident caused by the composite negligence of the drivers of a trailer-truck and of a bus. The question was whether the whole compensation could be recovered from one of them and how liability should be apportioned.

Held. In composite negligence the liability of each wrongdoer to the claimant is joint and several. The claimant may recover the whole amount from any one of them, and he is not required to sue all of them or to have the liability apportioned between them first. Apportionment as between the tortfeasors is a matter for them, by contribution among themselves, and does not affect the claimant's right to full compensation from any one.

Why it matters here. It is the practical rule that decides how a Claims Tribunal proceeds under section 168 of the Motor Vehicles Act 1988 when two vehicles are to blame, and it protects the claimant from being made to litigate the drivers' quarrel.

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