Vicarious liability in motor accidents extends to unauthorised driving during official duty when the act remains within employment.

A State employer may be vicariously liable where a government vehicle is used for official work and the negligent driving occurs in the course of employment, even if the person at the wheel was not the regular or formally authorised driver at that moment. Liability extends to an authorised act performed in an unauthorised or improper manner so long as the conduct remains within the sphere of employment and is not a purely independent venture. The statutory scheme on government vehicles and no-fault compensation supports a liberal approach protecting third-party victims. On that reasoning, responsibility for the accident remained fastened on the State and other liable parties.

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Issues: Whether the State was vicariously liable for the accident caused while the government jeep was being used for official duty, though the vehicle was being driven by an employee who was not the regular driver and was acting in an unauthorised manner.

Analysis: Liability in motor accident cases turns on whether the negligent act was sufficiently connected with the employer's business and was done in the course of employment. An employer is liable not only for acts expressly authorised, but also for an authorised act performed in a wrongful or improper manner, provided the act remains within the sphere of employment and is not a purely independent venture. The use of the jeep was found to be for official purposes, the regular driver was in charge of the vehicle, and the employee who was driving was also on official duty. The dispute related to the mode in which the authorised work was done, not to a departure from the employer's business. The statutory scheme relating to government vehicles and no-fault compensation reinforced a liberal approach in favour of third-party victims.

Conclusion: The State was vicariously liable for the accident and could not avoid responsibility on the ground that the vehicle was being driven by an employee not formally authorised to drive it at that moment.

Final Conclusion: The appeal failed and the compensation liability fastened on the State and the other liable parties remained undisturbed.

Ratio Decidendi: An employer is vicariously liable where an authorised act is carried out in an unauthorised manner in the course of employment, and third-party victim compensation cannot be defeated merely because the precise mode of execution was not expressly authorised.

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