A recent legal complaint highlights claims that a vehicle's design and safety features failed to protect its occupant during a post-collision fire, resulting in severe injuries. The lawsuit was filed by Jay Kharbanda in the United States District Court for the Eastern District of New York on May 4, 2026, naming Tesla, Inc. as the defendant.
According to the filing, Kharbanda was driving a 2024 Tesla Model 3 on June 30, 2025, when he was involved in a collision at the intersection of Old Country Road and Newtown Road in Plainview, Nassau County, New York. The complaint states that after an initial impact with another vehicle—a Hyundai operated by Lawrence Z. Levy—the Tesla struck a traffic control pole or other roadside object. Following this sequence of events, the Tesla allegedly caught fire due to what is described as a 'post-collision thermal event involving the high-voltage battery system.'
The plaintiff asserts that he suffered 'catastrophic burn injuries, severe pain and suffering, permanent disfigurement, emotional trauma, lost earnings, and other substantial damages' as a result of the incident. The complaint specifically claims that 'the Subject Vehicle’s post-collision fire, thermal runaway, egress-related hazards, and related defects' were responsible for enhancing his injuries beyond those caused by the initial crash.
Kharbanda’s legal team outlines several alleged defects in the vehicle’s design and manufacturing process. These include claims that the car was 'defectively designed, defectively manufactured, inadequately tested, insufficiently warned,' and not reasonably crashworthy. The suit further alleges that Tesla failed to provide adequate warnings about risks associated with post-collision fires and emergency egress procedures when electrical systems are compromised.
The document details how the Model 3’s ordinary door-release controls rely heavily on electrical power. In scenarios where power is lost—such as after a significant collision—the electronic door-release mechanism may become unavailable or unreliable. This situation requires occupants to use a separate manual release located near window switches. According to the complaint: 'Tesla’s separate manual release system was not sufficiently conspicuous, intuitive, fail-safe, or reasonably designed for a crash-and-fire emergency involving a disoriented, injured, smoke-affected or panicked occupant.'
The filing describes how Kharbanda attempted to escape from his burning vehicle under extreme conditions: 'During and immediately after the fire event, Plaintiff was forced to attempt escape from a burning Tesla under emergency conditions involving impact trauma, heat, smoke, panic and loss or degradation of ordinary electrical functionality.' It is alleged that these circumstances created an acute emergency where immediate egress was critical but hindered by design flaws.
The complaint accuses Tesla of being aware—prior to June 30, 2025—of potential dangers associated with high-voltage lithium-ion battery systems in foreseeable collisions. It states: 'Tesla knew or should have known that foreseeable crash damage to high-voltage lithium-ion battery systems could result in thermal runaway...and extraordinary rescue and suppression challenges.' Despite this knowledge from prior incidents and internal testing referenced in owner materials and first-responder documents provided by Tesla itself—the company allegedly did not adopt safer alternative designs or provide sufficient warnings.
Six causes of action are listed: strict products liability for design defect; strict products liability for manufacturing defect; strict products liability for failure to warn/instruct; negligence; breach of express warranty; and breach of implied warranty of merchantability. For each cause of action detailed across multiple paragraphs in the filing—including specific allegations regarding battery architecture flaws and inadequate manual egress mechanisms—the plaintiff contends these defects were substantial factors causing his injuries.
Kharbanda seeks compensatory damages for past and future pain and suffering; medical expenses; lost earnings; loss of earning capacity; emotional distress; disfigurement; punitive damages intended 'to punish Tesla and deter similar conduct'; costs; interest; as well as any further relief deemed just by the court.
The case identifies Antin Ehrich & Epstein LLP as attorneys for Jay Kharbanda. The civil action is docketed under Case No. 1:26-cv-02661.
Source: 126cv02661_Kharbanda_v_Telsa_Inc_Complaint_Eastern_District_New_York.pdf