THE TAMIL NADU NATIONAL LAW SCHOOL

ANALYZING THE PRODUCT LIABILITY ISSUE WITH THE CONTRACTUAL LAW

SUBMITTED IN THE PARTIAL FULFILLMENT OF B.COM. L.L.B (Hons.), THIRD SEMESTER

Submitted to: Prof. S. Deepika
Submitted by: Karan Kumar Khetani
Registration no: BCO140026

ACKNOWLEDGEMENTS
I have taken efforts in this project. However, it would not have been possible without the kind support and help
of many individuals and organizations. I would like to extend my sincere thanks to all of them.
I am highly indebted to the faculty of TNNLS for their guidance and constant supervision as well as for
providing necessary information regarding the project and also for their support in completing the project. I
would like to express my gratitude towards my parents and mentors for their kind cooperation and
encouragement which help me in completion of this project. I would like to express my special gratitude and
thanks to all for giving me such attention and time. My thanks and appreciations also go to my colleagues in
developing the project and people who have willingly helped me out with their abilities.

TAB L E O F C O N T E N T S
1. Abstract,.04

2. Introduction...05

3. Review of the Existing Literature.07

4. Case Study- The McDonalds Trouble.08

5. Conclusions and Suggestions....17

6. References.18

ABSTRACT
Introduction:
Product liability is the area of law in which manufacturers, distributors, suppliers, retailers, and others who
make products available to the public are held responsible for the injuries those products cause. Although the
word "product" has broad connotations, product liability as an area of law is traditionally limited to products in
the form of tangible personal property.

Objective:
The research work aims at revealing the real legal issues that have been time and again raised over the Concept
of Product Liability.

Scope:
The research project takes into its ambit certain questions such as what should be the extent till which product
liability can be fixed upon the producer or seller and till what quantum is the consumer liable for the products
he purchases and/or consumes.

Extent:
The research work would only cover the Indian Scenario and Case laws over the issue of Product Liability.

Research Methodology:
The research would follow the doctrinal research methodology.

INTRODUCTION
The next time you walk into a retail store like Wal-Mart, Target, Home Depot, Office Depot, Babies R Us/Toy
R Us, you will see a board, typically in plain sight of the viewing public, with sheets of papers titled Product
Recall or Safety Recall or something of the like. Recalled items run the gamut of consumers good and are
generally recalled because of a safety or health concerns. The Food and Drug Administration regularly issues
recalls or public safety notices for Medical Products, Pharmaceuticals, Tobacco, and contaminated food items.
Product Liability is the responsibility of manufacturers, distributors and sellers, they are expected to act in the
best interest of the public; to deliver a product free of defects which can harm an individual or persons; and to
make good on that responsibility if their products are defective. These can include faulty auto brakes,
contaminated baby food, exploding bottles of beer, flammable children's pajamas, or lack of label warnings. The
key element in products liability law is that a person who suffers harm from a product need not prove
negligence, since the negligence is "presumed" and the result is "strict liability" (absolute responsibility) on the
seller, distributor and manufacturer. An injured person usually need only sue the seller and let him/her/it bring
the manufacturer or distributor into the lawsuit or require contribution toward a judgment. (Gerald Hill, et al
2002). In the following paragraphs we will discuss and analyze the different types of product liability,
regulatory bodies involved in product recalls and or safety, legal issues regarding product liability and
ramifications of non-recalls.

Product Liability, at its core, is about consumer protection and safety. Firms have a legal obligation to not
purposefully sell harmful products to consumers, also they have the responsibility to recall defective products
when it is determined they cause injury or danger. Here are a few ways in which a manufactures can be held
responsible for the products they sell:
* Inherent Risks-Some products or services, medical procedures for example, come with an inherent risk that
the firm cannot mitigate. The firm must inform the consumer of these risks to lessen their liability.
* Design Defects-The design of the product may create a dangerous condition, a steam vaporizer whose center
of gravity is so high that the unit is likely to fall over. (Crawford, Di Benedetto) Second, the product may be
absent a safety device, a cold therapy machine that does not have an automatic shut off function for example.
Lastly, inadequate materials which deteriorate after usage, a car seat strap that breaks into piece when chewed
on by a child while riding in a car.
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* Defects in manufacturing-Even if the product is well designed the use of inadequate quality techniques may
result in a defective unit. An example would be a poorly welded chassis of a childs wagon toy.
* Inadequate instructions for use or inadequate warnings about dangers of misuse-firms have to take into
account all consumer behavior toward a products use. Warnings and instructions for use should be visible on the
product and direct the consumer on the appropriate use of the item in question. Improper labeling and
instruction could lead to a liability claim against the company for an injury sustained for improper use of a
product. An example of this would be the instructions car seat manufactures place on give for using the cars
seatbelt with the safety seat.

In India, Product liability law governs the liability of manufacturers, wholesalers, distributors and vendors for
injury to a person or property caused by dangerous or defective products. The goal of product liability laws is to
help protect consumers from dangerous or defective products, while holding manufacturers, distributors and
retailers responsible for putting into the market place products that they knew or should have known were
dangerous or defective.
The following Acts and Laws in India deal with the issue of Product Liability.
(i) Law of Torts as laid down by Courts through Precedents;
(ii) The Consumer Protection Act, 1986 (the CPA);
(iii) The Monopolies and Restrictive Trade Practices Act, 1969 (the MRTP Act);
(iv) The Sale of Goods Act, 1930;
(v) The Indian Contract Act, 1872.
The Research Study in question being a submission relating to the Contracts Act and the Sale of Goods Act, it
would majorly emphasize on these two topics in the essence.

R E V I E W O F E X I S T I N G L I T E R ATU R E
The issue of the analysis of Product Liability is not new. In fact, there have been more than a few Scholarly
Works which brilliantly put light on this important topic, a few of which are listed below.

Besterfield Dale H., Dale H. Besterfield, Carol Besterfield-Michna, Glen H. Besterfield, Mary
Besterfield-Sacre, Hermant Urdhwareshe, Rashmi Urdhwareshe | Pearson Education India, 2011 - Total
Quality Management

Sanjay Kaptan | Sarup & Sons, 01-Jan-2003 - Consumer Movement in India.

Harry Duintjer Tebbens | BRILL, 01-Jan-1979 - International Product Liability: A Study of

Comparative and International Legal Aspects of Product Liability

CASE STUDY | THE MCDONALDS TROUBLE

THE CASE OF LIEBECK VS. MCDONALDS:
Relentlessly controversial in nature, this case continued to be the answer to the journalists prayer until it was
settled. Liebeck vs. McDonalds aroused the interest of both the media and legal community and held public
attention for its lifetime. Initially, the case took off like most frivolous lawsuits in which the plaintiffs aim is to
milk the negligence of the organization for monetary gain. Generating continual momentum for the lawsuit was
the public empathy and identification with Liebeck in a classical little David and big, ugly Goliath setting. It
seemed clear that Liebeck was negligent in not exercising caution in handling her coffee but in the end, it was
found that MdDonalds was 80% responsible for the incident, while Liebeck was 20% at fault 1
Liebeck vs. McDonalds became a landmark case that has been used to argue in favor of a need for a change in
the interpretation and application of tort law in the legal environments.

THE PRODUCT AND PRODUCT SAFETY ISSUE

McDonald's Corporation is the global king of the fast food industry, operating over 31,000 restaurants on a
global scale with world-wide employees totaling more than 1.5 million people. The McDonalds Corporation,
famous for being the 6th most valuable brand globally according to the 2010 Interbrand Best Global Brands
report, is ranked as the #1 restaurant and provides food and beverage service to 60 million customers around the
world on a daily basis (Interbrand).
The size of the organization and the success of past financial windfall seekers serves as a continual
encouragement to people to look for ways in which they can have a bite of the fortune of the colossal
McDonalds Corporation fortune. The restaurant has ruggedly endured some frivolous lawsuit in its 70 years
existence, most of them having nothing to do with safety while the plaintiffs claim negligence on the part of the
organization, from that of NYPD cop John Florio (NY) and VjollcaLecaj ( sued for $600,000.00 in Chicago),
who filed individual cases against McDonalds for allegedly finding some pieces of glass in their chicken
sandwiches (McDonalds Lawsuits) to lawsuits for marketing happy meals to children, promoting bad health and
circumventing parental by giving them toys in happy meals (Los Angeles Times).

THE LAWSUIT
1 http://www.economicexpert.com/a/Stella:Liebeck.htm|
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On a fateful day of February, 1992, the foundation for the biggest lawsuit against McDonalds occurred when 79
year old woman, Stella Liebeck from Albuquerque, New Mexico rode with her grandson through the drive
through lane to purchase a 49 cent coffee cup. On receiving the cup, she placed it between her legs and
proceeded to open the cup in order to add some condiments when the scalding hot coffee poured unto her
thighs, bottoms and groin. The cotton sweat pants she wore made matters worse be absorbing the hot liquid,
resulting in some serious third degree burn over 6% of her body (OBrien, Shafner, Stuart, Kelly & Morris,
1999).
The elderly lady was admitted at the hospital and was there for eight days; her skin was grafted, lost 20 pounds
and also went through over a year of medical treatment, missing work. The initial amount sued for was just
$20,000.00 and the daughters lost wages (OBrien, Shafner, Stuart, Kelly & Morris, 1999) which McDonalds
met with a counteroffer of only $800.00 with a defense that the lady did not exercise diligent care and was
negligent because it is public knowledge that coffee is hot. As if taking offense to McDonalds response, her
attorney increased the requested compensatory damages and punitive damages to $100,000.00.

THE ISSUES
An experiment was carried which revealed that McDonalds coffee was much hotter than that provided by
similar services in the same locality at about 185 degrees Celsius which the organization claimed was required
to have the taste required. It was also revealed that many people had fallen prey to McDonalds coffee with
some victims sustaining 3rd degree burns similar to Stella Liebecks which serve as a precedence for the court
that McDonalds was aware of potential danger presented by their coffee (OBrien, Shafner, Stuart, Kelly &
Morris,1999).
The main issue being negligence involving tortuous liability but in order to stick to the contractual Law, we will
stick to the Manufacturers liability under Sales of goods Act and Indian Contracts Act.

THE LEGAL THEORIES

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The case also involves Negligence which is defined as the failure to exercise that degree of care that, in the
circumstances, the law requires for the protection of other persons or those interests of other persons that may
be injuriously affected by the want of such care and Reasonable care, which is the care amount or quality of
care that a reasonable person would exercise under the same circumstances, which doubles as the
standard for determining legal duty2.
Proximate cause is an event that is sufficiently related to a harm that has occurred to be considered a primary
cause of the harm. The question here that arises, was McDonalds coffee the causal reason for Ms. Liebecks
third degree burns? Did they foresee the occurrence of the occurrence? Breach of the care is defined as the legal
obligation imposed on a person with the requirement that they adhere to a reasonable standard of care while
performing (an) act or acts that could cause foreseeable harm to others, that is, did McDonalds know that their
coffee could cause injury to their customers?

THE RESOLUTION
The six man, six woman deliberated for four hours to arrive at $200, 000 compensatory damages which was
reduced by 20% and $2.7m in punitive damages, which also was reduced to $480,000 (Gallivan, White &
Boyd). By mutual agreement, McDonalds and the plaintiffs settled out of court for an undisclosed amount.

MY OPINION
Despite the fact that Liebecks situation was an accident, McDonalds breached their duty of care by not
sufficiently warning their customers of the potential danger that could result if customers did not handle their
hot coffee cups with utmost care. Also, customer safety should take precedent over the delivery of certain coffee
taste. If the organization had not been negligent in the observation of the duty of care, the injury would have
been averted. I am convinced that the proximate cause of 80% attributed to McDonalds and 20% attributed to
the plaintiff was very just.

THE AFTERMATHS
The news media, the day after the verdict, established that coffee at the McDonalds in Albuquerque is now sold
at 158 degrees. At that temperature, it would take about 60 seconds to cause third-degree burns, considerably
2 Steven H. Gifis, BARRON'S LAW DICTIONARY, (6th Ed, Barron's Educational Series, 2010)
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significantly reducing the risk factor in McDonalds coffee (Gallivan, White & Boyd). Therefore, McDonalds
was forced to exercise some level of corporate responsibility by reducing the temperature of its coffee and the
public was made aware of the potential danger of hot coffee. Worldwide, the company now uses much bigger
and legible warning on their coffee cups to prevent a reoccurrence of the Liebeck case.

REGULATORY AUTHORITIES
National Institute of Food and Drug Safety Evaluation, the Food and Drug Administration and US Food and
Drug Administration are some of the agencies in charge of regulating McDonalds operations and products. The
Food and Drug Administration is directly responsible for the oversight of McDonalds operations. The Food and
Drug Administration, FDA for short, has oversight of food safety, hygiene and substance generally recognized
as safe.

PREVENTION OF FUTURE OCCURRENCES

Working proactively with organizations like the Food and Drug Administration (FDA), Food and Drug Safety
Administration and the National Institute of Food and Drug Administration will help McDonalds prevent
similar reoccurrences of lawsuits. Also, the implementation of effective product liability management will go
very far McDonalds in preventing such frivolous lawsuits

CONTEXT AND LEGAL BASIS

In todays dynamic and innovative business environment, every day a new product is conceptualized by
designers/ manufactures and is put to display for sale to attract customers and earn huge profits. However, in
this pursuit, it may happen that the said product develops a defect for any reason which may have been
overlooked by the designers/ manufacturers in the hurry to launch the said product. Such situations result in
cases where due to a faulty or a damaged product the consumer suffers a loss or an injury. The said situation
coupled with an educated consumer (i.e. one who is aware of his rights) gives rise to a product liability claim
makes the situation difficult for the companies whose products are deficient. The jurisprudence relating to
product liability in India has been constantly evolving and in the recent times the Indian courts have also
adopted a pro-consumer approach while deciding on product liability claims. The courts in India are generally
guided by the principles of justice, equity and good conscience.
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Following the way paved by an English case of Donoghue v Stevenson which provided the principle of duty of
care, Indian Laws are also conditioned for protecting the consumers from any damage or injury caused due to
such faulty or dangerous products and holding the manufacturers and/ or distributors and/ or retailers and/ or
packers responsible for any such damage or injury.
The term product liability may be understood to be the liability of any or all of the parties along the
manufacturing and supply chain of a product, arising due to any damage or injury caused by such product.
Products containing inherent defects that cause harm to a consumer of the product are the primary subject
matter of product liability claims. In India there is no specific statute which governs the product liability claims
and the term product liability is also not defined under any Indian statute.
In the absence of any specific Indian statute the Indian product liability law can be said to have been emerging
from different Indian statues and the product liability claims could be ascertained under the following Indian
statutes/ laws (hereinafter together referred to as Indian Laws): the Consumer Protection Act, 1986 (CPA);
the Sale of Goods Act, 1930 (SGA); The Indian Contract Act, 1872 (ICA); Specific statutes pertaining to
specific goods such as the Food Safety and Standards Act, 2006, the Drugs and Cosmetics Act, 1940, the Legal
Metrology Act, 2009, etc. (hereinafter together referred to as Specific Statutes); and the Common Law
principles.3

Based on this legal framework, a product liability claim may be based on negligence, strict liability or breach of
warranty of fitness, depending on the respective law under which the claim is based. The most essential aspect
of product liability claim is that the defect must be proved.
These defects can be broadly categorized as design defects (i.e. inherent defects in the design of the product),
manufacturing defects (i.e. defects which occur during the manufacturing process of the product) or marketing
defects (i.e. relating to wrong or incomplete instructions/ warnings on the packaging of the product).

WHO CAN CLAIM

3 Besterfield Dale H., Dale H. Besterfield, Carol Besterfield-Michna, Glen H. Besterfield, Mary BesterfieldSacre, Hermant Urdhwareshe, Rashmi Urdhwareshe | Pearson Education India, 2011 - Total Quality
ManagementSanjay Kaptan | Sarup & Sons, 01-Jan-2003 - Consumer Movement in India.
Harry Duintjer Tebbens | BRILL, 01-Jan-1979 - International Product Liability: A Study of Comparative and International Legal
Aspects of Product Liability

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The availability of the right to claim product liability inter alia depends on the respective law under which the
case is proposed to be filed. Under the CPA, a complainant has been defined as a consumer, or a registered
voluntary consumer association or Central Government or the State Government, or more than one consumers
(where there are more than one consumers) having the same interest, and the legal heir or representative of the
consumer (in the event of the consumers death), who or which makes a complaint. The CPA defines a
consumer as a person who buys goods or hires/avails of any service for a consideration, including any user/
beneficiary of the goods/services other than the person who buys such goods/hires or avails such services for a
consideration, when such use is made/services are availed of with the approval of the first mentioned person. It
does not include a person: (i) who obtains such goods for resale or for any commercial purpose; or (ii) who
avails of such services for any commercial purposes.
However, under the terms of the SGA and the ICA, the buyer and the party to the contract, respectively have
the right to file a product liability claim.

DEFECTS AND STANDARD OF DEFECT

It is important to note that the defect and standard of defect pertaining to a product inter alia depends and varies
from one law to another. It is, therefore, possible that a claim relating to a particular defect may not be covered
under one law but squarely fall under the purview of the other.
For example, the CPA defines the term defect as any fault, imperfection or shortcoming in the quality, quantity,
potency, purity or standard which is required to be maintained by or under any law for the time being in force or
under any contract, express of implied, or as is claimed by the trader in any manner whatsoever in relation to
any goods. Therefore, a complaint in respect of any other defects which do not fall within the scope of the
above definition cannot be made under the CPA.
Under other laws, a product may be considered defective if: (i) an implied warranty or condition as to the
quality or fitness for any particular purpose for the product is breached; or (ii) the seller fails to fulfill its
fundamental obligation under a contract; in which case no term of the contract can relieve the seller of its
respective fundamental duty; or (iii) the statues governing specific goods require certain specific compliances
like branding, labeling etc., then, any breach or non-compliance of such requirements. Further, the standards by
which a product may be deemed to be defective also depends upon the terms and conditions of the contract
along with any warranties or guarantees provided under such contract.
LEGAL PROCEDURE
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The appropriate forum for filing a product liability claim inter alia depends on the respective law under which
the consumer wishes to file the complaint as well as the monetary relief sought. A claim under the CPA is
required to be filed in the District Consumer Forum/State Commission/National Commission, which have been
constituted under the CPA, depending on their respective jurisdiction. Under any other law, the basic
structure/hierarchy of the Indian courts will have to be followed. It may be noted that irrespective of the forum,
the burden of proof lies on the party alleging the defect. Further, the limitation period for filing a product
liability claim shall depend on the respective law under which the claim is sought. While the CPA provides the
limitation period of two years, other laws give three years from the date on which the cause of action (product
defect) has arisen.

POSSIBLE DEFENSES
Once the claim has been initiated by a consumer in an appropriate forum, the accused person may take defenses
such as: (i) product being compliant with statutory standards prescribed for the said product; (ii) defect being
caused by negligence of the consumer/ buyer; (iii) consumer/buyer had examined the goods prior to purchase;
(iv) contractually agreed warranties, waivers, disclaimers and limitation on liability; or (v) expiration of
limitation period. It is important to note that the permissibility of any of the aforesaid defenses shall be at the
sole discretion of the appropriate forum and also depend on the respective case.

PRODUCT LIABILITY CLAIMS REMEDIES AVAILABLE TO CONSUMER

Compensatory Damages: The court /forum may award compensation to the consumer/buyer for any loss or
injury suffered due to the negligence of the seller.
Non-Compensatory Damages: Under the terms of the ICA, the party who suffers loss on account of breach of
contract by the other party is entitled to receive, from the party who has breached the contract, compensation for
any loss or damage caused to it, which naturally arose in the usual course of things from such breach, or which
the parties knew, when they made the contract, likely to result from the breach of it. As per the Indian law,
indirect or consequential damages cannot be awarded. Moreover, damages such as incidental, special, punitive
and exemplary are not specifically provided for under the Indian law.
Other Damages: In terms of the applicable Indian Laws, any aggrieved party may claim for: (i) removal of
defect from the respective product; (ii) replacement of the product with a new product of similar description
which shall be free from any defect; (iii) refund of the purchase price; (iv) discontinuance of unfair trade
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practice or restrictive trade practice, as the case may be; (v) cease and desist orders in the manufacturing of
hazardous goods; or (vi) withdrawal of hazardous goods from being offered for sale.

CRIMINAL LIABILITY
The CPA provides that where a trader or a person against whom a complaint is made or the complainant fails or
omits to comply with any order made by the District Forum, the State Commission or the National Commission,
as the case may be, then, such trader or person or complainant be punished with imprisonment for a term which
shall not be less than one month but which may extend to three years; a fine, which shall not be less than 2,000
rupees but which may extend to 10,000 rupees; or both. Further, the provisions of the India Penal Code 1860 are
also enriched by the elements of cheating and fraud that are attributed to the defects in the products supplied to
the consumers. It is important to note that criminal liability may also arise in terms of the specific statues
depending on from case to case.
PRODUCT RECALL
Product recall is a request to return to the maker a batch or an entire production run of a product, usually due to
the discovery of safety issues. The recall is generally an effort to limit liability for corporate negligence (which
can cause costly penalties) and to improve or avoid damage to publicity. However, product recalls are costly to a
company because they often entail replacing the re-called product or paying for damage caused by use, although
possibly less costly than the costs caused by damage to brand name and reduced trust in the manufacturer.
Presently, India does not have any specific law or statute or provision which may mandatorily require a product
recall exercise to be undertaken.
RISK MITIGATION
A product liability claim has the potential of overthrowing any business. It is, therefore, essential for every
company to take adequate measures to shield itself from such potential damage. One of the means adopted by
companies across the globe is by procuring a product liability insurance cover. This protects the respective
companies from and against any losses suffered due to a product liability claim. It is, however, essential to read
and understand the exclusions provided under such insurance covers before purchasing them. The premiums to
be paid to the insurers in relation to such insurance covers are primarily based on the nature of the product (as
the risk and liability is directly linked to the nature of the product) and its sales volume (as this reflects the reach
of the product). This means that every company discloses the correct details of a respective product at the time
of procuring the respective product liability insurance cover.
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GOVERNMENTS INITIATIVE
The Indian government is taking significant measures to make consumers aware of their rights with respect to
any loss or injury caused due to a defective product, irrespective of their educational credentials. The Jago
Grahak Jago campaign was aimed at enhancing consumer awareness by advertizing the rights available to
them. The Union Ministry of Consumer Affairs also started the National Consumer Helpline Project (NCH
Project), a telephone helpline, to help consumers deal with a multitude of problems arising in their day-to-day
dealings with business and service providers. On a national toll-free number, a consumer can seek information,
advice or guidance for his/her queries, complaints and guidance. The NCH Project supports the consumers by:
(i) guiding consumers in finding solutions to problems related to products and services; (ii) providing
information related to companies and regulatory authorities; (iii) facilitating consumers in filing complaints
against defaulting service providers; (iv) empowering consumers to use available consumer grievances redressal
mechanisms; and (v) educating consumers about their rights and responsibilities.
APPROPRIATE INDIAN CASE: Uma Deepak V Maruti Udyog Ltd & Others (2003)CPJ 90 (MRTP).

C O N C L U S I O N AN D S U G G E S T I O N S

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In the light of the above discussion, it should be noted that it is important for a consumer to identify the correct
law before filing a product liability claim. If chosen wrongly, the claim may not be sustained in the respective
court or forum. It should also be kept in mind that the time taken by a respective court or forum in deciding the
claim may run into a couple of years inter alia. This should, however, not discourage the consumer to file a
product liability claim. Further, considering that damages such as incidental, special, punitive and exemplary are
not specifically provided for under the Indian law, the compensation amount which the customer receives may
at times be insignificant compared to the hardship suffered in pursuing the case. In this situation, one can say
that the initiatives being taken by the Indian government, which are playing an important role in educating the
consumers about their rights, may fall short of the desired result predominantly for two reasons -- (i) they are
CPA centric; and (ii) they do not provide a solution to the above issues/concerns.
One may, therefore, conclude this study stressing on the urgency to codify and consolidate the law governing
product liability under one specific statute.

REFERENCES
BOOKS:
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1.Besterfield Dale H., Dale H. Besterfield, Carol Besterfield-Michna, Glen H. Besterfield, Mary BesterfieldSacre, Hermant Urdhwareshe, Rashmi Urdhwareshe | TOTAL QUALITY MANAGEMENT, (Pearson
Education India, 2011)
2. Sanjay Kaptan, CONSUMER MOVEMENT IN INDIA, (Sarup & Sons, 01-Jan-2003)
3. Harry Duintjer Tebbens, INTERNATIONAL PRODUCT LIABILITY: A STUDY OF COMPARATIVE
AND INTERNATIONAL LEGAL ASPECTS OF PRODUCT LIABILITY (BRILL, 01-Jan-1979)

WEBSITES:
1. http://www.economicexpert.com/a/Stella:Liebeck.htm (Last Visited on 25 April, 2014)
2. http://doihavealawsuit.com/lawyer-attorney/personal-injury-lawsuit-lawyer/276 (Last Visited on 25 April,
2014)
3. http://indiainfoline.com/ (Last Visited on 25 April, 2014)
4. http://library.findlaw.com/1999/Nov/1/129862.html (Last Visited on 25 April, 2014)
5. http://www.isapindia.org/ (Last Visited on 25 April, 2014)

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