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Airbus Industrie G.I.E. v. Patel

[1998] UKHL 12, 1 AC 119 (H.L.) (1998)

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Airbus Industrie G.I.E. v. Patel

House of Lords

[1998] UKHL 12, 1 AC 119 (H.L.) (1998)

Facts

A plane crash caused by pilot error at the Bangalore airport in India killed and injured many passengers. Two Indian families were on board. All members of both families were British citizens and resided in London. Four members of the families were killed, and four were injured. The four injured family members (the British victims) (defendants) filed suit in India against India Airline Corporation and Hindustan Aeronautics, Ltd. The British victims filed another lawsuit in Texas against various parties potentially connected to the crash, including Airbus Industrie G.I.E. (Airbus) (plaintiff). The British victims’ case was consolidated with other proceedings filed in Texas on behalf of three American crash victims. Texas did not recognize the principle of forum non conveniens. Airbus initiated proceedings in a Bangalore court against the British victims and the American victims. The Bangalore judge barred the British victims and American victims from pursuing proceedings or claiming damages against Airbus anywhere except India. Because the Bangalore court had no jurisdiction over the British victims and American victims, the order was unenforceable against them. Airbus filed suit in England seeking enforcement of the Bangalore judgment against the British victims and requesting an injunction prohibiting the British victims from pursuing the Texas case. The trial judge denied Airbus’s request. The appellate court reversed. The British victims appealed to the House of Lords.

Rule of Law

Issue

Holding and Reasoning (Goff, J.)

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