Sanjay Gupta & Ors. vs State of Uttar Pradesh Through Its Chief Secretary & Ors.
Background
On 10 April 2006, a devastating fire broke out at the "India Brand Consumer Show," an exhibition organized at Victoria Park, Meerut, killing 65 people and injuring over 161 others. The victims/families filed this writ petition seeking compensation from the State and the private event organizers. An earlier State-appointed inquiry commission's report was rejected by the Supreme Court in 2015 for procedural unfairness, and the Court instead appointed retired Justice S.B. Sinha as a one-man Court Commission to determine the cause of the fire and apportion liability between the organizers, the contractor, and State authorities.
Decision Breakdown
The Court Commissioner found that the organizers had deliberately suppressed facts to obtain permissions, failed to comply with mandatory safety and electricity regulations (including provisions on generator installation), and misrepresented their fire-safety preparedness, while State officials, including the District Magistrate and police/fire authorities, were also negligent in inspecting the site and enforcing the law. The Commissioner apportioned liability 60% to the organizers and 40% to the State, applying the principle of res ipsa loquitur (the accident "speaks for itself" as evidence of negligence, given that a fire of this scale should not occur if reasonable safety care is taken). The Supreme Court accepted the Commission's report and this liability split, rejected challenges to the Commission's authority and findings, and directed that compensation for each victim/family be computed on the same basis as motor accident compensation claims, by a specially nominated judicial officer in Meerut, with existing ex-gratia and interim payments to be adjusted against the final amount.
Lesson Learnt
Event organizers who take on the responsibility of hosting large public gatherings owe a non-delegable duty of care to visitors regarding fire safety and statutory compliance, and cannot escape liability by blaming contractors; and government authorities that fail to enforce basic safety laws (fire, electricity, crowd control) share real legal responsibility for resulting tragedies.