Corr v IBC Vehicles Ltd
The suicide of a man who developed severe depression as a result of an accident at work did not break the chain of causation, and his employer was liable for his death.
Facts
Mr Corr was seriously injured at work, through his employer's negligence, when a machine malfunctioned, causing severe head injuries and disfigurement. He developed post traumatic stress disorder and severe depression, and six years after the accident, he killed himself by jumping from the top of a multi storey car park. His widow sued the employer for damages for his death.
Legal principle
The House of Lords held that the employer was liable for the death. Lord Bingham said that the suicide was not a voluntary, informed decision taken by a person in a position to make it, but was the result of the depression caused by the accident, so it did not break the chain of causation. Depression was a foreseeable consequence of the accident, and suicide was a known consequence of depression, so the death was not too remote. The defence of volenti did not apply.
Related cases on remoteness and intervening acts
- Hughes v Lord Advocate [1963] AC 837
- Jolley v Sutton London Borough Council [2000] 1 WLR 1082
- Knightley v Johns [1982] 1 WLR 349
- Lagden v O'Connor [2003] UKHL 64, [2004] 1 AC 1067
- Lamb v Camden London Borough Council [1981] QB 625
- McKew v Holland & Hannen & Cubitts (Scotland) Ltd [1969] 3 All ER 1621
- The Oropesa [1943] P 32
- Overseas Tankship (UK) Ltd v Miller Steamship Co Pty Ltd (The Wagon Mound (No 2)) [1967] 1 AC 617
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