Supreme Court Holds That Electricity Utilities Are Governed By The Rule Of Strict Liability, And Not Absolute Liability, In Claims Arising Out Of Electrocution

The Supreme Court of India, through its judgment dated 12.08.2026 in Karnataka Power Transmission Corporation Limited v. Rekha and Others¹, set aside concurrent orders of the High Court of Karnataka which had fastened absolute liability upon the Karnataka Power Transmission Corporation Limited (“KPTCL”) in respect of two electrocution incidents.

The appeals arose out of two separate incidents in Karnataka. Firstly, a person died upon coming into contact with an 11 kV transmission line, and secondly, a person suffered grievous injuries upon coming into contact with a 66 kV line while attempting to retrieve a cricket ball. The claimants approached the High Court of Karnataka by way of writ petitions. The learned Single Judge, and thereafter the Division Bench, awarded compensation by treating KPTCL as being absolutely liable and by applying the ‘multiplier method’ under the Motor Vehicles Act, 1988. KPTCL assailed both the maintainability of the writ petitions and the standard of liability adopted.

The principal issues before the Court were (i) whether a writ petition is maintainable where liability rests upon seriously disputed questions of fact; (ii) whether an electricity utility is governed by the rule of absolute liability or that of strict liability; and (iii) whether the multiplier method under the Motor Vehicles Act, 1988 can be applied to compensation claims arising out of electrocution.

The Court held that writ jurisdiction is not the appropriate remedy where the foundational facts are disputed and relegated the claimants to the appropriate alternate forum. On standard of liability, the Court distinguished the rule of strict liability in Rylands v. Fletcher² which has certain exceptions, which is different from the rule of absolute liability in M.C. Mehta v. Union of India³, which has no exceptions and applies to inherently hazardous industrial enterprises. Following Union of India v. Prabhakaran Vijaya Kumar⁴, the Court reiterated that it is strict liability which governs electricity-related accidents. Accordingly, an electricity utility, being engaged in an inherently dangerous activity and being best placed to distribute the loss through insurance or pricing, is liable to compensate the victim irrespective of proof of negligence, but retains the recognised defences to strict liability, such as an act of God or the claimant’s own default. The Court further held that the multiplier method under the Motor Vehicles Act, 1988 cannot be mechanically applied to electrocution claims, as the Electricity Act, 2003 prescribes no such method, notwithstanding that Section 57 thereof fixes the licensee’s liability to pay compensation.

Footnotes

^{1 SLP (C) No. 24849 of 2025.}

^{2 (1868) LR 3 HL 330.}

^{3 (1987) 1 SCC 395.}

^{4 (2008) 9 SCC 527.}

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