In Occupiers Liability Act 1984, persons as occupiers of premises are liable for injury suffered by persons other than their visitors. This includes trespassers and those who exceed their permission. It sets out the occupier's duty of care to trespassers. The duty is to take reasonable care to see that the trespasser is protected from dangers that the occupier knows about and can reasonably expect a trespasser to encounter. An occupier will only owe trespassers a duty to care for their safety:
- in respect of risks of which the occupier knows or has reasonable grounds to believe that they exist;
- if he knows or has reasonable grounds to believe that the [trespasser] is in the vicinity of the risks;
- If the risk is one against which he can be expected to offer some protection in the circumstances.
Tort of negligence
Negligence is a failure to exercise the care that a reasonably prudent person would exercise in like circumstances (Encyclopedia Britannica, Meriam Webster). The area of tort law known as negligence involves harm caused by carelessness, not intentional harm.
According to the course book, negligence is when the defendant:
- Causing loss by a failure to take responsible care when there is a duty to do so.
- The defendant may not wish to inflict injury but by carelessness he allows it to happen.
Negligence occurs when:
- Somebody does not exercise the standard of care that a reasonably careful person would use under the circumstances. (The standard of care is a way of measuring how much care one person owes another. For some people the standard of care is higher than others. Doctors, for example, have a higher standard of care toward others than the reasonable person.)
- Somebody does something that a reasonably careful person would not do under the circumstances.
In everyday life, negligence can arise in many situations, including: on the road, medical and health care, at work, at one’s property, faulty products, etc. Under the law of negligence there are several special types of liability and some groups are held to a higher standard of care than the average person. For example, consumers can sue a manufacturer of a product if the product is faulty or does not meet a required standard. The area of law that deals with negligence on the part of manufacturers is called product liability. People who own or occupy property have duty to maintain their property so that no one entering the property will be injured. This legal responsibility is called occupiers’ liability. Property owners must take particular care to protect children who may be enticed onto their property by an item such as a swimming pool. Items that might entice a child to enter someone’s property are known as allurements.
If found liable, wrongdoers must compensate victims in full for losses. On the other hand, if persons by their own fault cause or contribute to their own injuries, they will be held at least partly responsible for their damages under the contributory negligence defense.
Strict liability
Strict liability, sometimes called absolute liability, is the legal responsibility for damages, or injury, even if the person found strictly liable was not at fault or negligent. Strict liability has been applied to certain activities in tort, such as holding an employer absolutely liable for the torts of her employees, but today it is most commonly associated with defectively manufactured products.
The rule in Rylands vs. Fletcher applies strict liability on occupier. A person brings and keeps on land in his occupation anything likely to do mischief if it escapes must keep it in at his peril. If fail to do so, he is liable for all damage naturally accruing from escape even if the escapes occurs without negligence or want of care on his part.
Consumers who have been injured by defectively manufactured products also rely on strict liability. Under the doctrine of strict , a manufacturer must guarantee that its goods are suitable for their intended use when they are placed on the market for public consumption. The law of torts will hold manufacturers strictly liable for any injuries that result from placing unreasonably dangerous products into the stream of commerce, without regard to the amount of care exercised in preparing the product for sale and distribution and without regard to whether the consumer purchased the product from, or entered into a contractual relationship with, the manufacturer. In Greenman v. Yuba Power Products 1963 the California Supreme Court became the first court to adopt strict tort liability for defective products.
Injured plaintiffs have to prove that the item was defective, that the defect proximately caused the injury, and that the defect rendered the product unreasonably dangerous. A plaintiff may recover damages even if the seller has exercised all possible care in the preparation and sale of the product. Purchasers of the product, as well as injured guests, bystanders, and others with no direct relationship with the product may sue for damages caused by the product
Bright Light PLC vs Chemi-Kaze PLC
The fact: In the same premises on a retail park, Bright Light PLC sells light fitting on the first floor, Chemi-Kaze PLC sells industrial chemicals, stores large quantities of chemicals on the ground floor. A wiring fault in Bright Light causes a fire which escapes down to the ground floor causing damage to Chemi-Kaze. Some of the containers of chemicals outside the back door have become damaged in the fire causing rust to develop. Vandals rob some of the containers and unscrew the caps. Chemicals from the containers then seep out, escape into the next unit, Flower Power, a garden centre killing many of Flower Power’s stock of plants.
The problem: a fire which was caused in Bright Light PLC caused damage to Chemi-Kaze. Chemicals from Chemi-Kaze’s containers killed many of Flower Power’s stock of plants.
Analysis:
By statue (Occupier’s liability Act 1957 and 1984), a premises occupier takes responsibility for ensuring the Premises reasonably safe for all those who attend on it (Ward vs. Tesco stores ltd). Because Bright Light PLC and Chemi-Kaze PLC share their promises, their occupiers’ liability is also split specifically. Bright Light PLC is liable for the first floor as running business there and likewise Chemi-Kaze PLC is liable for the ground floor.
The wiring fault cause ignition of fire was the root cause of all the damage between the three parties. And the negligence of Chemi-Kaze PLC as letting the chemicals seep out is a joint cause.
The sudden ignition of fire deriving from Bright Light PLC area could be foreseeable as the business itself is aware of potential risks and hazards when doing electrical business. In this case, the fault is foreseeable because Bright Light PLC is selling electrical devices; where there is any fault can easily cause damage. By concerning the detail to legal aspect, Bright Light PLC has made a breach of occupier’s libability and ordinary negligence because Bright Light PLC did not exercise any appropriate Prevention to ensure the safety on its premises.
As Bright Light PLC is operating business in electrical equipments, it is liable for ensuring that its equipment would not cause damage to others in his premises. But due to the wiring fault, a fire was caused and escape to the ground floor causing damage to Chemi-Kaze PLC. in this case, Bright Light PLC is placed Strict liability which is the imposition of liability on Bright Light PLC without a finding of fault (such as negligence or tortious intent). Although the wiring fault caused a fire unexpectedly but because of having strict liability, Bright Light PLC must be liable for the damage under the Rule in (Rylands vs. Fletches 1868)
In case of Chemi-Kaze PLC, it is liable for the ground floor where it doing business, especially when it is doing chemical business, it has a duty to ensure all the chemicals is safely preserved and cannot cause damage to other. The chemicals from unscrewed-cap in containers seep out, escape into the Flower Power, killing many plans. The escape of chemicals could be foreseeable as the business itself is aware of potential risks and hazards when doing chemicals business. Concerning the detail to legal aspect- Chemi-Kaze PLC has made a breach of occupier’s liability and ordinary negligence because Chemi-Kaze PLC did not exercise any appropriate prevention to ensure the safety on its promises. It just left the container outside the door and didn’t take any action to protect the damaged-containers of chemicals. Moreover, as selling chemicals, Chemi-Kaze PLC is placed strict liability, according to the rule in Rylands vs. Fletcher: “a person brings and keeps on land in his occupation anything likely to do mischief if it escapes must keep it in at his peril. If fail to do so, he is liable for all damage naturally accruing from escape even if the escapes occurs without negligence or want of care on his part.”
Conclusion:
Bright Light PLC is liable for Chemi-Kaze PLC’s loss since it has act a negligence. Chemi-Kaze PLC can claim damages.
Chemi-Kaze PLC is liable for Flower Power since its negligent act. Flower Power can claim damages.
3.3. Vicarious liability
3.3.1. General vicarious liability
Vicarious liability is a form of , that arises under the doctrine of – – the responsibility of the superior for the acts of their subordinate, or, in a broader sense, the responsibility of any third party that had the "right, ability or duty to control" the activities of a violator (Source: Wikipedia). A person who did not cause the injury has a particular legal relationship to the person who did act negligently. It is also referred to as imputed . Legal relationships that can lead to imputed negligence include the relationship between parent and child, , owner of a vehicle and driver, and employer and employee.
For example, a is generally for the performed in the course of the agent's assigned by the principal; and an for the action or inaction of an in the normal course of her or her or duties
3.3.2. Employer’s liability
Employers are the group most commonly held vicariously liable. are vicariously liable, under the doctrine, for negligent acts or omissions by their employees in the course of (Source: Wikipedia)
The most important element to establishing a case for vicarious liability is that the wrongdoer be acting as a servant or employee, and that the wrong done be connected to the employee's course of employment. Vicarious liability can only be imposed if it is proved that the employee was acting “in the course of employment.” For example, if the driver of a gasoline delivery truck runs a red light on the way to a gas station and strikes another car, causing injury, the gasoline delivery company will be responsible for the damages if the driver is found to be negligent. Because the company will automatically be found liable if the driver is negligent.
They have been charged when an employee is charged with sexual harassment, discriminatory behavior towards potential employees or customers, and any other situation where an employee somehow causes harm to another. An employer can be roped into a legal situation regardless of whether the employee is acting against policies set by the employer or following the rules to the letter.
Even though the employer is not the one who committed the unlawful act, the employer is held liable because it is considered responsible for its employees' actions while they are on the job and it is considered to be able to prevent and/or limit any harmful acts performed by employees. The employer may be able to avoid vicarious liability by exercising reasonable care to prevent the unlawful behavior.
3.3.3. Health and safety issues
Health and Safety at Work etc Act 1974
Often referred to as HASAW or HSW, this Act of Parliament is the main piece of UK health and safety legislation. The Act defines general duties on , , , suppliers of goods and substances for use at work, persons in control of work premises, and those who manage and maintain them, and persons in general. It places a duty on all employers "to ensure, so far as is reasonably practicable, the health, safety and welfare at work" of all their employees.
Among other provisions, the Act also requires:
- Safe operation and maintenance of the working environment, plant and systems
- Maintenance of safe access and egress to the workplace
- Safe use, handling and storage of dangerous substances
- Adequate training of staff to ensure health and safety
- Adequate welfare provisions for staff at work.
Management of Health and Safety at Work Regulations 1999
The Management of Health and Safety at Work Regulations 1999 places a duty on employers to assess and manage risks to their employees and others arising from work activities.
Employers must also make arrangements to ensure the health and safety of the workplace, including making arrangements for emergencies, adequate information and training for employees and for health surveillance where appropriate.
Employees must work safely in accordance with their training and instructions given to them. Employees must also notify the employer or the person responsible for health and safety of any serious or immediate danger to health and safety or any shortcoming in health and safety arrangements.
3.3.4. Scenario analysis
Anthony vs Maria
The fact: Anthony ran a fish restaurant. One day, he switched on his fish-fryers in order to warm the oil but he fell asleep. The oil in the fryers overheated and burst into flames. Fire officers arrived to extinguish the fire. Titus, a fire officer, rushed into the restaurant’s kitchen in order to extinguish the flames, knocking over an open can of the stored olive oil. The oil caught fire and increased the intensity of the fire. It spread rapidly through Anthony’s restaurant then spread to Maria’s dry cleaning shop, which was situated next door. The dry-cleaning chemicals stored in Maria’s shop to ignite caused an explosion. Two people were burned and showered. Sam, a police officer, was trying to persuade a crowd that had gathered outside the shop, to leave the area of danger. The other was Hugh, aged 10, who had come to watch the fire. Both Sam and Hugh received severe and burns from the explosion. Hugh, who had a weak heart, suffered a heart attack as a result of the shock of his injuries and died in hospital a week later.
The problem: In Anthony restaurant, the oil which were warmed in the fryers overheated and burst into flames. The fire spread to Maria shop causing an explosion. Hugh & Sam received severe and burns from the explosion. Hugh died later.
Analysis:
As mentioned in 3.3.2-employer liability, employers are the group most commonly held vicariously liable. are vicariously liable, under the doctrine, for negligent acts or omissions by their employees in the course of . However, to limit the exposure to the tortfeasor and limit vicarious liability, employer can establish clear policies for employee’s behavior on job and enforce them to carry out. In case the employees cause damages or injuries on the job, the employer may be able to escape liability by showing that actions were not in course of the employment as in the case of General Engineering Services Ltd. v Kingston and Saint Andrew Corp. 1989. To claim for damage, plaintiff have to show that the tortfeasor was actually in the employment relationship with that employer and the negligence act occurred in the course of his employment (Honeywill v Larkin 1934).
In this case, concerning in detail the action of Titus, his action is held liable by his employer and the damages he caused to Maria’s premise is obvious. He knocked over the opened oil can causing high intensive of the fire and more serious damage. However, his employer can advocates that Titus was just doing what is right and necessary as a fireman would do in such emergence circumstance. Moreover the opened oil can was unforeseeable, and the can would ignite fire sooner or later regardless the action of Titus because it was opened. Therefore Titus and his employer were not liable for the damage of Maria’s shop or Anthony’s restaurant.
On the other hand, Sam’s employer could be held vicariously liable for the damage of Hugh because Sam has made a negligence that he didn’t take care of Hugh as duty of a police. Sam has duty of ensuring the crowd as well as Hugh are at the safe place but he has breach his duty as not paying attention to Hugh and letting him injured. Furthermore, Sam was doing his job under the course of employment; therefore his employer is vicariously liable for his negligence.
Regarding to health and safety issue, according to the Health and Safety at Work Act 1974, every employer must have:
- General duties to persons other than their employees and;
- General duties of persons concerned with premises to persons other than their employees.
This regulation can also be applied in this case. As Anthony and Maria are doing their own business that is self-employment, they owed a duty to persons other than employees, which is stated in the Act that they are responsible to ensure, so far as is reasonably practicable, their undertaking is reasonably careful, that they and other persons (other than employees) who may be affected thereby and not thereby exposed to risks to their health or safety. Furthermore, Anthony and Maria also owe duties of persons concerned with premises, in which, they are liable to persons (other than their employees) relating to their health and safety. Both Anthony and Maria breached their duties relating to health and safety because Anthony whose the root cause of the negligence and Maria involved in the negligence chain and their negligence caused injury to Sam and death to Hugh.
On the other hand, the case of Sam and his employer is an exception. According to Common Sense, Common Safety, October 2010: “Police officers should not be at risk of investigation or prosecution under health and safety legislation when engaged in the course of their duties if they have to put themselves at risk as a result of committing a heroic act”. Therefore, Sam’s employer is not liable for his injury concerning to his health and safety.
Conclusion:
Anthony and Maria are liable for the injury of Sam and the death of Hugh. They have to compensate Sam for his injury and compensate Hugh’s parents for his death.
Sam’s cannot claim his employer for damage concerning to his injury. But his employer could not escape such liabilities for instance, employment insurance.
4. Elements of tort of negligence
To succeed in a tort of negligence action, the claimant must prove three issues. Firstly, the defendant owed them a duty of care. Secondly, the defendant was in breach of that duty. Thirdly, the particular acts or omissions were the cause of the loss or damage sustained. Lastly the claimant suffered damage caused by the defendant’s breach.
Duty of care
The first is the duty of care that must exist in the first instance. A duty of care is the obligation to avoid careless actions that could cause harm to one or more persons. It was established in Donoghue v. Stephenson (1932). This case established the principle that everyone is under a legal obligation to take reasonable care to ensure that others will not be injured because of careless conduct.
The claimant will have to prove that the defendant owed him a duty of care in the first instance. However, further to this it is reasonable to expect the negligent party to have been able to foresee that their act would be negligent, this was established in Bourhill v. Young (1943) and King v. Phillips (1953) both these cases established that the duty of care must be "foreseeable". It would be unreasonable and unjust to hold someone responsible for something that was unexpected, or of a freak nature.
Breach of duty
The next important element is that the duty of care which is imposed on the defendant must be breached. The duty is said to be breached when the duty is said to occur as per the standards of the reasonable prudent person and the same standard is not met by the defendant. What is the standard varies from person to person is different from an expert.
The concept of breach of duty was originally defined in Blyth v. Birmingham Waterworks Co. (1856), this established that the breach of duty of care is based upon the actions of a "reasonable man." This means that the defendant was acting unreasonably, or outside of his normal duties Paris v. Stepney Borough Council (1951). Professional people (those people with a higher level of skill than the average man) must conduct themselves with the skill expected of that profession, Carmarthenshire C.C. v. Lewis (1955).
Causation
For a defendant to be held , the claimant must prove, on the balance of probabilities, that the defendant's breach of duty caused the loss. If the victim cannot prove that the person acted wrongfully was the cause the loss, he will not be entitled to any compensation, despite his own innocence.
Causation has two prongs. First, a tort must be the cause in fact of a particular injury, which means that a specific act must actually have resulted in injury to another. In its simplest form, cause in fact is established by evidence that shows that a tortfeasor's act or omission was a necessary antecedent to the plaintiff's injury. Courts analyze this issue by determining whether the plaintiff's injury would have occurred "but for" the defendant's conduct. If an injury would have occurred independent of the defendant's conduct, cause in fact has not been established, and no tort has been committed. When multiple factors have led to a particular injury, the plaintiff must demonstrate that the tortfeasor's action played a substantial role in causing the injury.
Second, plaintiffs must establish that a particular tort was the legal cause (or proximate cause) of an injury before liability will be imposed. Proximate cause is evaluated in terms of foreseeability. The claimant has to show that the type of damage was reasonably foreseeable. If the defendant should have foreseen the tortuous injury, he will be held liable for the resulting loss. If a given risk could not have been reasonably anticipated, proximate cause has not been established, and liability will not be imposed. Proximate cause becomes very important when the relationship between the unreasonable act and the injury is remote, calling into question the foreseeability of the injury. Proximate cause is also important when there are many causes of an injury — as when a negligently set campfire combines with a lightning strike to burn a barn.
This is seen in the case of The Wagon Mound (1961) where fuel had negligently spilled onto water in a harbor. Two days later the oil caught fire because of wielding work being done on another ship. The fire spread to the claimants wharf and burnt it. The damage suffered was not reasonably foreseeable.
Damage
Finally there must have been damage caused to the claimant, the damage need not be to the claimants, but can also be to his property. The damage must be reasonably foreseeable Re: Wagon Mound (1961) and must be directly contributable to the defendants' actions. However, in Re: Polemis (1921), even acts that are unforeseeable can be held to be direct enough to establish negligence.
For example, a person driving a car has a general duty to conduct the car in a safe and responsible manner. If a driver runs through a red light, the driver violates that duty. As it is foreseeable that running a red light can result in a car crash, and that people are likely to be injured in such a collision, the driver will be liable in negligence for any injuries that in fact result to others in a collision resulting from the running through the red light.
Damages may be physical, psychological, and emotional injury. Specifically, these injuries may include permanent disability, pain and suffering, disfigurement, humiliation, embarrassment, distress, impairment of earning capacity, lost wages or profits, medical costs, and out-of-pocket expenses. The law allows plaintiffs to be compensated for physical injuries, mental and emotional injures, and monetary injuries as long as those injuries are actually suffered.
An example case is Vaughan v Menlove (1837).
The fact: Defendant paced a haystack near cottages owned by Plaintiff. Defendant was warned that there was a substantial possibility that the hay would ignite, and Defendant replied that he would “chance it”. The hay eventually did ignite due to poor ventilation and burn Plaintiff’s cottages, and Plaintiff sued to recover for their value.
In this case, the defendant owes a general duty of care to his neighbor, to “person so closely directly affect by my act that I ought reasonably to have them in contemplation as being so affected”. He has a responsibility for ensuring his premise is reasonable safe and not cause harm to others and their premises. He is also aware and warned that haystack might catch fire if the ventilation is poor. But he disregarded these warnings and kept the hay in place, did not take such reasonable care to prevent damages. Therefore he has breach his duty of care. The factual causation in this case is that the hay could ignite anytime. Eventually the haystack ignites and cause damage to claimant’s cottages.
Defendant was bound to act as a reasonable man would have under the circumstances. He was to be judged by the standard of a reasonable man.
Anthony vs Maria
The fact: Anthony ran a fish restaurant. One day, he switched on his fish-fryers in order to warm the oil but he fell asleep. The oil in the fryers overheated and burst into flames. Fire officers arrived to extinguish the fire. Titus, a fire officer, rushed into the restaurant’s kitchen in order to extinguish the flames, knocking over an open can of the stored olive oil. The oil caught fire and increased the intensity of the fire. It spread rapidly through Anthony’s restaurant then spread to Maria’s dry cleaning shop, which was situated next door. The dry-cleaning chemicals stored in Maria’s shop to ignite caused an explosion. Two people were burned and showered. Sam, a police officer, was trying to persuade a crowd that had gathered outside the shop, to leave the area of danger. The other was Hugh, aged 10, who had come to watch the fire. Both Sam and Hugh received severe and burns from the explosion. Hugh, who had a weak heart, suffered a heart attack as a result of the shock of his injuries and died in hospital a week later.
The problem:
In Anthony restaurant, the oil which were warmed in the fryers overheated and burst into flames. The fire spread to Maria shop causing an explosion. Hugh & Sam received severe and burns from the explosion. Hugh died later.
Analysis:
The duty of care: By statue (Occupier’s liability Act 1957 and 1984), a premises occupier takes responsibility for ensuring the Premises reasonably safe for all those who attend on it (Ward vs. Tesco stores ltd). In addition, the
Anthony and Miranda are responsible for ensuring their premises are reasonably safe. Furthermore, as both of them are doing business, where there are many visitors, thus ensuring safety in their premises is important.
Titus has a standard duty of care of a fireman. He has a duty of extinguish the fire as a reasonable fireman would do.
Sam has a standard duty of care of a reasonable police officer. He is responsible for ensuring the safety of the crowd, persuade the crowd to move to a safe area.
Breach of duty of care:
Anthony has breached his duty of care since he has left the oil overheated causing fire. He also left the oil can opened, near the fryer. The fire spread to Miranda shop causing an explosion. He made negligence as making his premise not safe regarding to occupier liability.
When Titus was attempting to extinguish the fire, he knocked over an open can of the stored olive oil. However, he was just doing “What is right and necessary” in an emergency situation. Furthermore, the opened oil-can could not be foreseeable, Titus could not know whether there is anything can ignite like oil. Moreover, assembly without the actions of Titus, sooner and later, the can of olive oil would be ignited as contacting to the blaze and led to the same damage because it had already been opened. Therefore, Titus didn’t breach his duty of care and was not be liable for that.
In case of Miranda, due to the chemicals in her shop, the fire got intensive and caused explosion causing hurt to Sam and death to Hugh. However, Miranda did not breach her duty of care because the fire is unforeseeable, and she has taken reasonable care for her premises.
Sam has a duty of persuade the crowd to move to a safe place. But he didn’t pay attention to Hugh, making him suffered damage. Thus he has breach his standard duty of care as failed to perform as a reasonable man.
Factual causation:
A restaurant is where there are many things could ignite and cause fire such as gas stoves, oil, etc. Similarly there are many things in dry cleaning shop can ignite and cause fire like irons, clothes, chemicals.
The two shops were next to each other which is a great condition for fire to spread.
Damages:
The fire from Anthony’s restaurant spread to Miranda’s shop causing explosion.
The explosion caused injury to Sam and caused death to Hugh later due to the shock of his injury.
Due to Sam negligence, Hugh suffered injury and shock resulting in his death.
Conclusion:
Anthony is liable for causing damage to Miranda’s shop due to his negligence. Therefore Maria can claim for damages.
Titus is not liable for causing the fire became intensive because he was just doing his duty of a firemen and the oil-can was not foreseeable.
Miranda is not liable for the explosion and Sam’s injury and Hugh’s death since the fire is unforeseeable.
Sam is liable for the death of Hugh. Hugh’s parents can claim for damages.
II. CONCLUTION
Tort is very common in real life, particularly tort relating to business. After learning about some aspects of the tort, it is important to understand tortuous liability, the tort of negligence and its nature of liability as well as its elements. With application the tortuous liability and liability in negligence in real life case, it helps understand clearly about tort so that can avoid making common negligent mistakes.
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