Causation:- Causation is the "causal relationship between conduct and result".

That is to say
that causation provides a means of connecting conduct with a resulting effect, typically an injury.
In criminal law, it is defined as the actus reus (an action) from which the specific injury or other
effect arose and is combined with mens rea (a state of mind) to comprise the elements of guilt.
Causation is only applicable where a result has been achieved and therefore is immaterial with
regard to inchoate offenses.
But for test:-

To demonstrate causation in tort law, the claimant must establish that

the loss they have suffered was caused by the defendant. In most cases
a simple application of the 'but for' test will resolve the question
of causation in tort law. Ie 'but for' the defendant's actions, would the
claimant have suffered the loss? If yes, the defendant is not liable. If no,
the defendant is liable. Causation may be problematic where there exists
more than one possible cause. Various formulations have evolved to ease
the burden of proving causation in such situations.

The 'But for' test

For application of the 'but for' test in establishing causation in
tort law see:
Barnett v Chelsea & Kensington Hospital [1969] 1 QB
428
Case summary

Facts[edit]
Three men attended at the emergency department of the hospital run by the Chelsea &
Kensington Hospital Management Committee but the casualty officer, Dr Banerjee, did not see
them, advising that they should go home and call their own doctors. One of the men died some
hours later. The post mortem showed arsenic poisoning which was a rare cause of death.

Judgment[edit]
It was held, that on the 'but for' test, even if the deceased had been examined and admitted for
treatment, there was little or no chance that the only effective antidote would have been
administered to him in time. Although the hospital had been negligent, because it was more likely
than not that he would have died anyway, the negligence was not the cause of death.

jobling v Associated Dairies [1982] AC 794 House of Lords

Mr Jobling, a butcher, slipped on the floor at his place of work due

to his employer's negligence. He injured his back which caused

him to reduce his earning capacity to 50% of what it was. He
then developed an independent back condition which was
unrelated to the injury which left him unable to work. The trial
judge applied Baker v Willoughbyand held that the claimant was
entitled to recover damages beyond the onset to the back
condition. The employer appealed.

Held:
The House of Lords distinguished Baker v Willoughby and stated
where the victim is overtaken before trial by a wholly
unconnected and disabling illness, the decision had no
application. The House of Lords were critical of the decision
inBaker v Willoughby but stopped short of overruling it.
Hotson v East Berkshire Area Health Authority [1987] AC
750 House of Lords
The claimant as a school boy fell out of a tree from a height of 12
foot. He suffered a fracture to his hip and was taken to hospital.
The hospital failed to diagnose his fracture and sent him home.
He was in severe pain so he was taken back to hospital 5 days
later where an X ray revealed his injury. He was treated and
suffered an avascular necrosis which resulted in him having a
permanent disability and a virtual certainty that he would develop
osteoarthritis. According to medical evidence, had he been
correctly diagnosed initially there was a 75% chance that he
would have still developed this condition, but there was a 25%
chance that he would have made a full recovery. The trial judge
awarded damages of 11,500 based of 25% of 46,000 which
was what would have been awarded if the claimant had shown
that the defendant's conduct had caused the avascular necrosis of
the hip.
Held:
The claimant had failed to establish on the balance of probabilities

that the defendant's breach of duty had caused the necrosis since
there was a 75% chance that it was caused by the fall. Therefore
the claimant was not entitled to receive anything in respect of the
necrosis.

Break in the chain of causation

When this occurs, the courts interpret this to mean that the accuseds conduct was not
the cause of the harm or injury.
A break in the chain of causation means that the courts have interpreted events and decided that the
accuseds conduct was not the cause of the harm or injury. This is unusual but when it does occur it
will result in the accused being acquitted. A break in the chain of causation arises where there is a
new intervening act or novus actus interveniens.
In these circumstances it may not be appropriate to find the defendant responsible for the eventual
outcome as others have played an important part in bringing this about. The law may still want to
blame the accused for the way in which he or she acted, but the law will also want to hold others
responsible for the part they played if they were the main contributor to the outcome.

South Australia Asset Management Corp v

York Montague Ltd
Facts[edit]
In the South Australia case, a valuer had (in breach of an implied term to exercise reasonable
care and skill) negligently advised his client bank that property which it proposed to take as
security for a loan was worth much more than its actual market value. The question was whether
he should be liable not only for losses attributable to the deficient security but also for further
losses attributable to a fall in the property market. The House decided that he should not be
liable for this kind of loss.

Carslogie Steamship Co v Royal Norwegian

Government
Facts[edit]
On 26 November 1949 the vessel Heimgar, while under time charter to the Ministry of Transport,
suffered damage in a collision with the Carslogie. It was admitted that the Carslogie was solely to
blame. Temporary repairs to the Heimgar were affected in England before she departed to the
United States, where permanent repairs were to be carried out. During the Atlantic crossing, the
ship sustained storm damage, which necessitated further repair. The Heimgar was in dock for
fifty days whilst repairs were carried out for both the collision damage and the storm damage. It
had been agreed that ten days would be allocated to the collision repair and thirty days for the
weather damage. The owners of the Heimgar claimed damages for the ten days in port
attributable to the collision damage.

Judgment[edit]
The owners of the Carslogie were held liable only for the loss suffered by the Heimgar which was
a direct result of the collision with the Carslogie. The House of Lords held that the storm was
a novus actus interveniens that broke the chain of causation.[1] The defendant was not liable for
any subsequent loss that arose from the storm encounter.