Padmavati vs Dugganaika Case
🔹 Case Name: Padmavati vs Duggannaika
🧾 Facts of the Case:
Padmavati was the owner of a bullock cart.
Her servant (driver) was driving the cart.
Two strangers (bystanders), including Duggannaika, got into the bullock cart without being invited or authorized.
While the cart was in motion, one of the wheels came off, and the cart overturned.
As a result, the two strangers were injured—one of them died due to the accident.
The cause of the accident was a defect in the axle of the cart, which the servant could not have known about.
❓ Legal Issue:
Whether Padmavati (the owner) was liable for the injuries/death of the persons (including Duggannaika) who were unauthorized passengers in the bullock cart?
⚖️ Court’s Reasoning and Judgment:
No Invitation or Permission:
The persons injured had not been invited by the servant or by Padmavati.
They voluntarily got into the cart without permission.
Lack of Negligence:
The accident was not due to negligence on the part of the driver or owner.
The axle broke due to a hidden defect that could not have been detected with reasonable care.
Application of Volenti Non Fit Injuria:
The strangers had voluntarily taken the risk of travelling in a bullock cart without any right or invitation.
Since they assumed the risk knowingly, they could not claim damages for any injury caused.
No Duty Owed to Unauthorized Persons:
The court emphasized that no legal duty was owed by the cart owner or driver to unauthorized persons who chose to enter the vehicle on their own.
🧑⚖️ Final Decision:
The court held that Padmavati was not liable for the injuries or death of the strangers (including Duggannaika), because:
There was no negligence.
The injured party had voluntarily accepted the risk.
The legal principle of volenti non fit injuria applied.
📌 Legal Principle Established:
If a person voluntarily and knowingly exposes themselves to a risk, they cannot later claim compensation for harm resulting from that risk.
🔍 Summary:
| Element | Explanation |
|---|---|
| Parties | Padmavati (owner) vs Duggannaika (unauthorized passenger) |
| Incident | Injury due to cart accident |
| Cause | Hidden defect in axle (no negligence) |
| Legal Issue | Liability for injury of unauthorized passenger |
| Defense Used | Volenti non fit injuria |
| Outcome | No liability on owner |
💡 Why This Case Is Important:
It sets a precedent for how unauthorized access and assumption of risk can negate liability.
It’s a classic tort case used in law schools to illustrate the defense to negligence claims.
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