UPSC MainsLAW-PAPER-II201920 Marks
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Q12.

A goldsmith putting earring to woman's ear does not require as much care as a surgeon performing surgery on the ear of woman." Elaborate the law relating to degree of care required under the law of tort.

How to Approach

This question tests understanding of the standard of care in tort law, specifically negligence. The approach should involve defining negligence, explaining the 'reasonable man' test, and then differentiating the degree of care required based on professional skill and context. The answer should highlight how the standard isn't uniform and depends on the activity undertaken. Structure: Introduction defining negligence, Body explaining the standard of care with examples and case law, and Conclusion summarizing the principle.

Model Answer

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Introduction

The law of torts deals with civil wrongs that cause harm to another, leading to legal liability. Negligence, a significant component of tort law, arises when a person fails to exercise the level of care that a reasonably prudent person would have exercised under the same circumstances. This ‘reasonable person’ standard isn’t absolute; it’s flexible and adapts to the specific context and the skills of the individual involved. The statement "A goldsmith putting earring to woman's ear does not require as much care as a surgeon performing surgery on the ear of woman" aptly illustrates this principle – the degree of care expected varies directly with the potential risk and the expertise demanded by the activity.

The Standard of Care in Negligence

The cornerstone of negligence is the duty of care. Once established, the defendant must meet a specific standard of care. This standard is typically defined by the ‘reasonable man’ test – what would a reasonably prudent person do in similar circumstances? However, this is a broad guideline, and the standard is adjusted based on several factors.

Factors Influencing the Degree of Care

Several factors influence the degree of care required. These include:

  • Nature of the Activity: More dangerous activities demand a higher standard of care.
  • Foreseeability of Harm: If harm is reasonably foreseeable, a higher degree of care is required to prevent it.
  • Special Skill or Expertise: Individuals possessing specialized skills (like doctors, engineers, architects) are held to a higher standard than those without such skills.
  • Relationship between Parties: Certain relationships (e.g., doctor-patient, teacher-student) create a heightened duty of care.

Professional Negligence and the Bolam Test

When dealing with professionals, the standard of care isn’t simply that of a ‘reasonable person’ but of a ‘reasonable professional’ in that field. The landmark case of Bolam v Friern Hospital Management Committee (1957) established the ‘Bolam test’ for medical negligence. This test states that a doctor is not negligent if they have acted in accordance with a practice accepted as proper by a responsible body of medical opinion, even if other doctors hold a different view. This test has been extended to other professions as well.

Applying the Principle to the Goldsmith and Surgeon Example

The initial statement highlights this difference perfectly. A goldsmith performing a relatively simple procedure like inserting an earring is expected to exercise ordinary care – ensuring the earring is clean, the instrument is safe, and the procedure is performed without undue force. The risk of serious harm is low.

Conversely, a surgeon performing surgery on the ear involves a complex procedure with a significantly higher risk of serious complications (infection, nerve damage, hearing loss). Therefore, the surgeon is held to a much higher standard of care. They must possess the necessary skill, knowledge, and experience, follow established medical protocols, obtain informed consent, and exercise meticulous attention to detail. Failure to do so constitutes negligence.

Illustrative Table: Comparing Standards of Care

Profession Activity Standard of Care Potential Risk
Goldsmith Earring Insertion Ordinary Care – cleanliness, safe instruments, gentle procedure Low – minor irritation, infection
Surgeon Ear Surgery High – specialized skill, knowledge, adherence to protocols, informed consent High – infection, nerve damage, hearing loss, complications from anesthesia
Driver Driving a Car Reasonable Care – obeying traffic laws, maintaining vehicle, attentive driving Moderate – accidents, injuries

Recent Developments & Considerations

While the Bolam test remains influential, it has faced criticism for potentially shielding negligent professionals. The Montgomery v Lanarkshire Health Board (2015) case in the UK clarified the duty to provide adequate information to patients, emphasizing patient autonomy and informed consent, adding another layer to the standard of care for medical professionals.

Conclusion

In conclusion, the degree of care required under the law of tort is not a fixed standard but a flexible one, tailored to the specific circumstances. The ‘reasonable person’ test serves as a baseline, but it’s significantly adjusted based on the nature of the activity, the foreseeability of harm, and, crucially, the skill and expertise of the individual involved. The goldsmith and surgeon example perfectly illustrates this principle – higher skill and greater risk necessitate a correspondingly higher standard of care to avoid liability for negligence.

Answer Length

This is a comprehensive model answer for learning purposes and may exceed the word limit. In the exam, always adhere to the prescribed word count.

Additional Resources

Key Definitions

Bolam Test
A standard used to determine negligence in professional malpractice cases, stating that a professional is not negligent if they acted in accordance with a practice accepted as proper by a responsible body of professional opinion.

Key Statistics

According to the National Crime Records Bureau (NCRB), India witnessed 5.5 lakh cases of unintentional injuries in 2022, many of which could potentially involve negligence claims.

Source: NCRB, Crime in India Report 2022 (as of knowledge cutoff)

A 2018 study by the Indian Journal of Medical Ethics found that medical negligence cases account for approximately 5-10% of all civil litigation in India.

Source: Indian Journal of Medical Ethics (as of knowledge cutoff)

Examples

Slip and Fall Accidents

A supermarket failing to clean up a spilled liquid, leading to a customer slipping and falling, is a classic example of negligence. The supermarket has a duty of care to maintain a safe environment for its customers.

Frequently Asked Questions

What is 'Res Ipsa Loquitur'?

Res Ipsa Loquitur ("the thing speaks for itself") is a doctrine that allows a plaintiff to establish negligence based on circumstantial evidence when the accident is of a type that ordinarily doesn't occur without negligence, the defendant had exclusive control over the instrumentality causing the injury, and the plaintiff's injury wasn't due to their own actions.

Topics Covered

LawConstitutional LawTort LawTort LawNegligenceDuty of CareStandard of Care