Examiners discuss 2017 tort law exam on negligence duties

Examiners’ reports 2017
LA2001 Tort law – Zone B
Introduction
Overall, candidates demonstrated a good knowledge of legal principles and
competence in terms of application of those principles to hypothetical scenarios and
discursive/critical essay questions. The addition of the compulsory essay question
(part A) – now in its second year – has been extremely positive in terms of enabling
students to develop research and critical evaluation skills. As the comments on
specific questions will illustrate, more attention needs to be focused on:
(a) Essay writing
(b) The evaluative elements of the compulsory essay
(c) Problem questions that raise several discrete legal issues.
Comments on specific questions
PART A
Question 1
Candidates must answer this COMPULSORY question about the article N J
McBride, ‘Michael and the future of tort law’ (2016) 32(1) Journal of
Professional Negligence.
a) What do you understand to be the distinction between what the
author describes as the ‘uniform’ and ‘policy’ approach to
determining whether a public body owes a duty of care to an
individual harmed by a third party?
b) Why does the author claim that the basis of the decision in the
House of Lords case of Hill v Chief Constable of West Yorkshire
(1988) has been misunderstood in subsequent cases and in
academic case commentary?
c) Why do you think the UKSC struck out the claim in the case of
Michael insofar as it related to the common law of negligence but
allowed the claim under Article 2 of the ECHR to proceed?
d) What do you consider to be the author’s primary contribution to our
understanding of the duty of care concept in this article?
General remarks
a) The information for this part is contained on p.2 and between pp.4–8.
Candidate responses to this part were strong – with most candidates
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grasping the point that the uniform approach makes no distinction between
duties of public bodies and those placed on private persons.
b) The information for this part is mainly found on pp.3 and 4. Candidates did
not consistently provide correct answers to this part. While most understood
that the author claims that the legal basis of the Hill decision has been
misunderstood, many failed to grasp the significance of the author’s
argument regarding Lord Keith’s judgment. The Zone B Examiners’ report
contains a student extract, indicating how this part ought to have been
addressed.
c) The information for this part is mainly to be found between pp.8–11. This
section of the article contained the most challenging arguments – being
philosophical in orientation. Examiners correctly took account of these
challenges when marking this part. Candidates, in general, tackled this part
well – most demonstrating understanding of the distinction between private
rights and public duties.
d) See common errors (below) and student extract/comments on extract.
Law cases, reports and other references the examiners would expect you to use
No references beyond the article were required.
Common errors
Common errors tended to occur in relation to part (d), and were indicative of a need
for greater attention in the module guide and supporting materials to critical
evaluative skills. Examiners were advised to expect different approaches to this part
and were advised to mark answers in an expansive spirit. Nevertheless, too many
answers were either repetitive of later answers or purely descriptive. Only a minority
of answers convincingly summarised what was distinctive about the author’s
contribution, such as:
 Re-appraisal of the Hill case
 Emphasising the public law/private law distinction that the courts are
grappling with.
A good answer to this question would…
relate the uniform approach to the pure omissions rule.
Perceive the connection between the policy approach and the just, fair and
reasonable limb of the Caparo test.
Demonstrate understanding that both the uniform and policy approach allow judges
to take account of questions of public policy.
Understand the relevance of the author’s argument regarding Lord Keith’s judgment
in Hill.
Demonstrate an understanding of the distinction between private rights and public
duties.
Understand the relevance of human rights principles to the case (HRA claim).
Provide at least one compelling reason for saying that the article makes an
important contribution to the understanding of tort law.
Demonstrate good preparation of the compulsory article.
Poor answers to this question…
demonstrated a poor reading of the article.
Failed to grasp the distinction between the uniform and policy approach.
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Student extract
Lord Keith in the final paragraph of his judgment in Hill made reference to the
fact that it was a positive thing that public bodies are not liable for such
omissions as it would be against the public interest for them to be held liable.
This use of ‘public’ interest in his language has caused many commentators
and judges to misidentify Hill as being a decision based on public policy and
the policy approach as opposed to the uniform approach.
Comments on extract
That academic and judicial understanding of the duty concept have been
significantly influenced by a misreading of Hill is a key element of the author’s
argument – and, arguably, his most significant contribution to the literature on tort.
The extract is indicative of the candidate’s careful reading of the article, and sound
appreciation of the case histories the article engages.
PART B
Question 2
‘An important achievement of the Defamation Act 2013 is in making certain
groups (such as journalists, website operators and academics) more
conscious of the need for careful and responsible publications.’
Discuss.
General remarks
The question aims to test candidates’ knowledge of, and ability to apply, principles
introduced by the 2013 Defamation Act.
Module guide, Chapters 19 and 20.
Defamation Act, ss.1(1), 1 (2), 4, 5, 6 and 8.
Loutchansky v Times Newspapers Ltd (Nos 2–5) (2002).
Metropolitan International Schools Ltd v Designtechnica Corporation, Google UK
and Google Inc (2011).
British Chiropractic Association v Singh (2010).
Tamiz v Google Inc (2013).
Cooke v MGN Ltd (2014).
Common errors
A significant minority failed to address the question of academic/scientific journals.
explore a sample of the following:
 Search engine liability – Metropolitan International Schools Ltd v
Designtechnica Corporation, Google UK and Google Inc (2011) and Tamiz
v Google Inc (2013)
 Section 5 protection – on forums, blog sites and search engines who print,
distribute and host user-generated content. Noting that it is a defence that
is defeated where the operator acted with malice in respect of posting the
statement but not defeated just because the website operator moderates
the statements posted by others. Noting also that the single publication rule
(s.8 of the Defamation Act 2013) addressed particular difficulties for internet
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publication and those operating online archives, Loutchansky v Times
Newspapers Ltd (Nos 2–5) (2002)
 Section 6 defence relating to material in scientific or academic journals –
whether published in electronic form or otherwise, which has undergone a
responsible peer review process, British Chiropractic Association v Singh
(2010)
 Specifically in relation to journalists – the question of the impact of the s.4
defence for publications on a matter of public interest – does it reflect the
Reynolds principles?
Good answers would note that the above instances of expanded liability are likely to
be offset by:
 Fewer actions against journalists: s.1(1) of the Defamation Act 2013 –
serious harm; Cooke v MGN Ltd (2014) – prompt apology/no specific
evidence that the article had caused serious harm/failed to meet the s.1(1)
threshold
 Especially from corporate claimants: s.1(2) provides that harm to the
reputation of a body that trades for profit is not ‘serious harm’ unless it has
caused or is likely to cause that body serious financial loss.
tended to give a general description of the terrain, with insufficient balance toward
2013 innovations.
Question 3
Jason is a high achieving employee at Egsheds, a recruitment agency.
Knowing Jason was ambitious Ela, the Human Resources manager at
Egsheds, decided to play a practical joke on Jason and so she sent him what
appeared to be a formal letter terminating his employment. Upon reading the
letter Jason collapsed. The lighted cigarette that Jason was holding fell into a
waste paper basket that was full of paper. Jason’s office was soon engulfed
in flames. When Fenella, Jason’s long term girlfriend and also an employee of
Egsheds, was informed that a fire had started in Jason’s office she
immediately collapsed. She was later diagnosed with post-traumatic stress
disorder. The fire crew arrived shortly afterwards but not in time to save
Jason. Peter, a fireman on his first emergency call, took one look at Jason’s
lifeless body and collapsed in shock. The fire had spread to a neighbouring
office and, fearing further loss of life, Samantha, another member of the fire
crew, entered the burning building. Happily, no-one was in the office and
Samantha also managed to escape being burned. However, Samantha, who
had recently recovered from diagnosed organic depression, suffered a
recurrence of the condition and is now unable to work.
Discuss the issues arising in the tort of negligence.
General remarks
This is a relatively straightforward question on psychological injury that, as is often
the case, produced strong answers overall.
Wilkinson v Downton (1897).
Alcock v Chief constable of South Yorkshire Police (1991).
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Walker v Northumberland County Council (1995)

Page v Smith (1996).
White v Chief Constable of South Yorkshire Police (1999).
Hatton v Sutherland (2002).
Common errors
A common error was the failure to distinguish between the two rescuers –
Samantha who can rely on Page and Peter who would be debarred because of
White. Also, not addressing the Wilkinson v Downton claim.
apply Wilkinson v Downton (1887) to Jason’s situation.
Note that the scenario is not clear on where Fenella was at the time of the incident.
If she was so placed as to be in fear of danger, she is a primary victim. However, it
is likely that she is a secondary victim who will fail on the relationship/proximity and
means of perception requirements.
Note that Peter/rescuer will succeed only if he were at risk of physical injury, White
v Chief Constable of South Yorkshire Police (1999). The evidence indicates that
Peter is a mere bystander.
Note that Samantha/rescuer appears to be in a similar position as the claimant in
Page v Smith (1996). We are informed that she ‘managed to escape being burned’,
which (unlike the other rescuer, Peter) places her in the zone of danger.
Credit was given to answers that noted that employees may have claims against
employers in certain circumstances where they have been exposed to work-related
stress, Walker v Northumberland County Council (1995) and Hatton v Sutherland
(2002). Special control mechanisms for psychiatric harm claims arising from
accidents (as laid down in Alcock) do not apply to claims for psychiatric injury
arising from occupational stress. However, it is unlikely that this these cases will
apply to Fenella’s situation.
were weak on the distinction between primary and secondary victims. They also
failed to grasp that a rescuer must fall into the primary or secondary victim category.
Question 4
Soraya’s house includes a very large room that is used as a playroom for her
twin daughters (Megan and India), aged six. As a special birthday treat,
Soraya contracted with David to build, in the playroom, a play house large
enough to comfortably accommodate four children. The work was delayed on
a number of occasions but David informed Soraya that the play house was
suitable for accommodation on the day of the twins’ birthday party. David
also informed Soraya that some adjustments needed to be made to the floor
of the playroom, so as to create some steps up to the play house. He advised
Soraya to warn anyone entering the play house that the ground may be
unsafe. In the excitement of the event, Soraya forgot to either put up a
warning notice or advise her guests of the state of the premises and because
of the unsafe ground, Jean, the grandmother of one of the child guests, fell
and sustained serious injury to her hip. Worse was to come when two
children (Matthew and Sebastian) were seriously injured when the roof of the
play house collapsed on to them. Matthew was an invited guest but Sebastian
had climbed into the playroom, through an open, low placed, window,
attracted by the look of the play house and by the party food that was
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displayed in the play house. Devon, another child guest, was taken seriously
ill after eating an egg that was infected with the salmonella bacteria.
Advise all parties of their rights and liabilities.
General remarks
This is a straightforward question on occupiers’ liability – for which students
generally achieved good marks.
Module guide, Chapter 16.
Occupiers’ Liability Act 1957, ss.1(2), 2(1), 2(2), 2 (3)(a) and 2(4)(a).
Glasgow Corporation v Taylor (1922).
Occupiers’ Liability Act 1984, s.1(3).
Haseldine v CA Daw & Son Ltd (1941).
Woodward v Mayor of Hastings (1945).
Jolley v Sutton London Borough Council (2000).
Common errors
Failure to note that Devon’s injuries did not arise from the state of the premises.
Note that in the case of Matthew, s.2(3)(a) determines that Soraya must be
prepared for children to be less careful than adults.
Note that in relation to Toy Builders, s.2(4)(b) will require Soraya to prove that she
acted reasonably in entrusting the work to them Haseldine v CA Daw & Son Ltd
(1941); Woodward v Mayor of Hastings (1945) KB 174.
Note that Sebastian is a trespasser and that the 1984 Act, s.1(3) determines that it
must be established that Soraya was aware of the danger, had reasonable grounds
to believe Sebastian was in in the vicinity and could reasonably be expected to offer
him some protection – noting a possible allurement, Glasgow Corporation v Taylor
(1922); Jolley v Sutton London Borough Council (2000).
Note that Devon must rely on the common law of negligence, since the danger did
not arise from the state of the premises.
Student extract
The visitor is only covered by the 1957 Act so long as he is behaving as
authorised. The overarching duty in the 1984 Act is for the occupier to
behave with ‘common humanity’ (BRB v Herrington). The duty in the 1984
Act is found only when three points have been satisfied…only if all three
points are satisfied does the duty apply (s.1(4)) and the occupier should take
such care as is reasonable in the circumstances to see that the non-visitor is
safe. Failure to satisfy these points was evident in Donoghue v Folkestone
where the defendant occupier successfully argued that it had no reason to
suppose that someone would dive…
Comments on extract
The extract is a well-written summary of the underlying principles governing
Sebastian’s claim. Without being inappropriately abstract/academic, the extract
shows a very good understanding of the interaction between the two OLAs, and the
historical development of the core content of the duty under the 1984 Act.
Poor answers to the question…
made reference to the OLAs but provided little or no explanatory case law.
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Question 5
Liam has been employed as a physical education teacher for 30 years at the
same school, Perfect Academy. He has always taught pupils between the
ages of 13 and 16. Liam was dismissed from his employment a year ago and
has since been unable to secure employment as a teacher.
The circumstances of his dismissal related to an accusation from a 13 year-
old-boy, Kym, that Liam had punched him during a football training session.
A formal investigation was conducted by an independent Human Resources
consultant, Diego. The report concluded that Liam had punched the boy,
despite Liam’s repeated denials. On the basis of the report, the head teacher
dismissed Liam. Errors and inaccuracies in the investigation report have
since come to light. The report claimed that the investigator had interviewed
Kym, but this was found to be impossible since Kym was out of the country
and not contactable at the time at which the interview was stated to have
taken place. Further, two pupil witnesses present at the time of the alleged
assault, who could have supported Liam’s account, were not interviewed.
Liam, who had just reached the early retirement threshold of 55 when he was
dismissed, invested 50% of his entire pension in Doonot Industries, after
scrutinising the audited accounts produced by Matt of ABC Accountants.
Significant errors were found in the audited accounts and Liam lost his entire
investment.
Advise Liam on whether he can recover his financial losses in the tort of
negligence.
General remarks
This was a relatively straightforward question on negligence resulting in pure
economic loss. To maximise marks, candidates needed a clear understanding of
the different approaches to cases where the negligent misstatement is made to
the person who suffers from financial loss, in contrast to those cases where the
negligent statement is made to a third party.
Module guide, Chapters 2, 5, 6, 10 and 13.
White v Jones (1995).
Spring v Guardian Assurance Ltd (1995).
Montgomery v Lanarkshire Health Board (2015).
Hedley Byrne v Heller Partners (1964).
Caparo Industries plc v Dickman (1990).
Common errors
A common error was in applying the Bolam test to establish breach of duty in cases
of financial advice.
A good answer to the question would…
note that the claim in respect of the discipline investigation and dismissal falls
within the category of pure economic losses in which the negligent misstatement
is made to someone other than the individual who suffers financial loss (e.g. White
v Jones; Spring v Guardian Assurance Ltd (1995)).
A good answer would deploy the Montgomery v Lanarkshire case, which displaces
Bolam in cases where an allegation of negligence relates to medical or financial
advice.
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Note that the claim against the accountant falls within the standard Hedley/Caparo
scenario, and is likely to fail.
Note also that Liam is likely to be challenged to show per Caparo Industries v
Dickman (1990) that Matt Slynn knew that his statement would be communicated to
Malik – either as an individual or as a member of an identifiable class.
applied the Caparo/Hedley test to the entire scenario, neglecting White/Spring. In
general, these answers displayed limited knowledge of case law.
Question 6
Jenny decided to celebrate her 40th birthday by, for the first time in her life,
joining a local gym, Step Up. The practice in Step Up is to devote the first
session – of one hour duration – to a health check-up, including heart and
blood pressure checks – and a session with one of the personal trainers, who
would demonstrate the equipment and draw up an exercise routine to suit the
gym member.
Jenny was assigned to Magdela, a personal trainer of 15 years’ experience at
a number of well-known gyms. Magdela failed to read up on the Step Up
protocols and so did not conduct the health check. In her defence, Magdela
claimed that gyms do not usually conduct health checks and, therefore, even
if she had known of the Step Up requirements, she would not have
considered it necessary to carry out the health checks.
All seemed to be going well until Jenny suffered agonising pain as a result of
a twisted muscle, caused by pulling onto a weight too quickly and without
engaging the correct posture. Jenny was taken to hospital where she also
developed chest pains. Within an hour of her arrival at the accident and
emergency department of Toddington Hospital, Jenny went into cardiac
arrest (heart attack). It transpired that Jenny had a heart problem which would
have been revealed if the health checks had been performed.
Saviour, the junior doctor in charge, was so anxious to deal with the cardiac
arrest that he completely forgot to deal with the muscle strain problem.
Unfortunately, the muscle injury was more serious than had been thought and
Jenny is now permanently disabled.
Advise Jenny to her rights and liabilities in the tort of negligence.
General remarks
While this is a relatively straightforward question, focusing on breach of duty and
causation, it was not answered as well as I would have expected. This is indicative
of a need to emphasise to students that they require a good general working
knowledge of the tort of negligence.
Caparo Industries plc v Dickman (1990) – for note only.
Bolam v Friern Hospital Management Committee (1957).
Barnet v Chelsea and Kensington Hospital Authority (1969).
Bolitho v City and Hackney AHA (1998).
Wilsher v Essex AHA (1986) CA.
Hotson v East Berkshire AHA (1988) – discounting its application.
8
Common errors
Many candidates devoted far too much space to the discussion of the duty of care.
as regards breach of duty, note that Magdela would be said to be offering a special
skill and would be brought within the Bolam test. It is likely that breach will be
proved since she neglected a routine health check, which appears to be established
practice in the gym.
Note that causation may prove challenging – the Bolitho (1998) decision may well
yield a conclusion that the harm would have been caused anyway.
Note that the intervention of the medical team is unlikely to constitute a nova causa,
since intervening medical advice would have to be desperately careless.
Note that Bolam applies, as confirmed by Wilsher – in the context of a junior doctor.
Note that although we do not know whether earlier diagnosis would have prevented
the disability, loss of chance (Hotson) will not be available and Jenny will have to
establish on the balance of probabilities that the disability would have been avoided
by proper diagnosis.
Consider contributory negligence, since we are advised that Jenny did not adopt the
correct posture when pulling at the weights.
tended to spend too much time on duty, to cope reasonably well with breach but
demonstrated weaknesses in terms of understanding the principles of causation. In
short, poor answers indicated a weak overall knowledge of principles of negligence.
Question 7
‘The defence of ex turpi causa (illegality) is overly punitive and really has no
place in the law of torts.’
Discuss.
General remarks
This question was intended to enable students to exercise a certain freedom in
scope. Examiners were instructed to exercise academic judgement as regards the
balance of potential themes.
Law Commission The illegality defence in tort.
Pitts v Hunt (1991).
Clunis v Camden and Islington Health Authority (1998).
Vellino v Chief Constable of Greater Manchester (2002).
Gray v Thames Trains Ltd (2009).
Joyce v O’Brien (2013).
Delaney v Pickett (2012).
Common errors
A common error was the elaboration of legal principle without addressing the issue
of fairness/justice demanded by the question.
9
address a good range of the following themes:
 Clunis v Camden and Islington Health Authority (1998), the court ought not
to allow itself to be made an instrument to enforce obligations alleged to
arise out of the claimant’s own criminal act.
 Gray v Thames Trains Ltd (2009), Lord Hoffmann’s comment that the
maxim ex turpi causa expresses not so much a principle as a policy.
 Vellino v Chief Constable of Greater Manchester (2002), escaping from
arrest sufficiently serious to allow ex turpi causa.
 Pitts v Hunt (1991), applied because of the defendant’s own criminal and
disgraceful conduct.
 Joyce v O’Brien (2013), Elias LJ observed that, given that the doctrine is
one of public policy, there should be some flexibility in its operation. It will
not apply to minor traffic offences but in most joint criminal liability cases
the nature of the principal offence will determine which acts of a co-
conspirator will attract the application of the doctrine.
 Delaney v Pickett (2012) was not defeated by ex turpi causa, the Court of
Appeal held that the accident did not happen because of the joint criminal
activity; the accident was caused by negligent driving and the possession of
illegal drugs was incidental to this.
 Seldom operates as a complete bar to liability; there is an overlap between
volenti and ex turpi causa.
Good answers would also draw upon the Law Commission The illegality defence in
tort.
demonstrated little knowledge of criticism in the field, including that within the Law
Commission report.
Question 8
Jo is a senior consultant in Easyjobs, a recruitment consultancy. All senior
consultants have sole occupancy offices and Jo was lucky to have secured a
large office on the ground floor, leading into a large paved courtyard.
Easyjobs had a strict policy against its consultants bringing ‘guests’ into
offices. Jo had arranged a meeting with one of the firm’s most lucrative
clients, David, who had flown over from New York especially for the meeting
at which it was expected that Jo would secure a one million pound contract.
Unfortunately, Jo’s dog sitter was unwell on the day in question and Jo was
unable to find anyone to care for her dog (Bob) whose aggressive behaviour
demanded close attention. At her wits end, Jo decided to bring Bob into the
office, with the intention of keeping him in the paved area during her meeting
with David. The meeting was progressing very well indeed when David caught
a glimpse of Bob. Being very fond of dogs, David rushed to the patio door and
opened it, whereupon Bob leapt on to David, pushing him over toward a
heavy glass table on which he struck his head and died instantly.
General remarks
This question required students to address employee status as well as course of
employment – the question was relatively evenly balanced between these two
elements of vicarious liability.
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Ready Mixed Concrete v Minister of Pensions (1968).
Century Insurance Co Ltd v Northern Ireland Road Transport Board (1942).
Lister v Hesley Hall (2001).
Limpus v London General Omnibus Co (1862).
Rose v Plenty (1976).
Common errors
Although students were not expected to dwell on the nature of the tort, a common
error was to neglect mention of this requirement. Also, a significant minority
neglected discussion of employee status.
note that the question is not clear on the issue of employee status – Jo is a
consultant – the issue should be discussed in the context of the Ready Mixed
Concrete case, since it is unlikely that the notion of relationship akin to employment
will apply to anything as conventional as a consultancy.
Note that the only relevant tort here is negligence and address the core
requirements – albeit briefly – with a focus on breach of duty – noting that the steps
Jo took to protect David from the risk of harm created by a dog known to be
aggressive appear to be less than adequate.
Demonstrate understanding of the Lister ‘close connection’ test. The key issue
here concerns expressly prohibited acts: does the situation fall within Limpus v
London General Omnibus Co (1862) or Rose v Plenty (1976)?
were weak on the application of the Lister test.
Student extract
These case[s] show that courts are well-prepared to hold an employee liable
even in cases where the employee deliberately deviates from standing
instructions. This may help David’s estate in a claim against
Easyjobs…David’s estate should stress that Jo was still carrying out the job
he was employed for (regarding business deals) albeit in a wrong way.
Comments on extract
This is a well-written and succinct paragraph that contains the core principles
underlying the cases on course of employment. The extract also demonstrates the
candidate’s ability to apply principles to the hypothetical case scenario.
Question 9
‘Duty of care and remoteness of damage share similar, if not the same,
functions.’
Discuss, with illustrative case law.
General remarks
This was a challenging question and a variety of legitimate approaches were given
due credit. However, the thrust of the question calls for an evaluation of the function
of duty and remoteness in excluding claims where reasons of policy are thought to
dictate an adverse result (from the point of view of the claimant).
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Module guide, Chapters 3, 5, 6, 9 and 13.
The Wagon Mound (No.1) (1961).
Hughes v Lord Advocate (1963).
Doughty v Turner Manufacturing Co (1964).
Caparo Industries v Dickman (1990).
Common errors
Answers tended to provide descriptive accounts of both duty and remoteness,
without considering the question of how the two concepts are related.
 note that the foreseeability test functions in duty and remoteness in similar
ways in respect of damage actually suffered by the claimant;
 draw on remoteness cases which are concerned with the categorisation of
different types of loss – e.g. Hughes v Lord Advocate (1963); Doughty v
Turner Manufacturing Co. (1964). Candidates should discuss how this
preoccupation aligns with considerations at the duty stage.
Note that duty and remoteness cases are often justified by explicitly invoking policy
arguments.
Place discussion within the context of the aims of tort and the function of duty and
remoteness in attaining the stated aims. Noting that both duty and remoteness
operate against the general philosophical background underpinning tort law – that
losses should lie where they fall; only exceptionally should someone other than the
party injured bear those losses.
misdiagnosed the question or failed to demonstrate clarity over how duty differs
from breach, and remoteness differs from factual causation.
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Examiners’ reports 2017

Examiners’ reports 2017

LA2001 Tort law – Zone B

Comments on specific questions

Walker v Northumberland County Council (1995)

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