Is the doctrine of sovereign immunity as laid down in steam navigation case still relevant?
The doctrine of sovereign immunity as laid down in steam navigation case is outdated and a historical anarchism. It is a product of colonial era. In modern times when the activities of the state have vastly increased and it is very difficult to draw a distinction between sovereign and non-sovereign functions of the state. The increased activities of the state have made a deep and pervasive impact on all facts of an individual life, and therefore, the liability of the state should accordingly be made co-extensive with the modern role of a welfare state and not to be confined to the era of a laissez faire (individualism) which the Peninsular and Oriental Steam Navigation case signifies.