Young v Bristol Aeroplane Co Ltd
The Court of Appeal is bound by its own previous decisions, subject to three exceptions.
Facts
Mr Young was injured at work and claimed damages from his employer for breach of statutory duty. He had already received compensation under the Workmen's Compensation Acts. Earlier decisions of the Court of Appeal had held that a worker who had accepted workmen's compensation could not also sue for damages. Mr Young argued that the Court of Appeal was not bound to follow those decisions.
Legal principle
The Court of Appeal held that it was bound by its own previous decisions, and dismissed the claim. Lord Greene MR said there were only three exceptions: where there are two conflicting decisions of the Court of Appeal, the court can choose which to follow; where a decision of the Court of Appeal, though not expressly overruled, cannot stand with a later decision of the House of Lords; and where the earlier decision was given per incuriam, that is in ignorance of a relevant statute or binding authority. These exceptions still govern the civil division of the Court of Appeal.
Related cases on judicial precedent
- Attorney General for Jersey v Holley [2005] UKPC 23, [2005] 2 AC 580
- Austin v Southwark London Borough Council [2010] UKSC 28, [2011] 1 AC 355
- British Railways Board v Herrington [1972] AC 877
- Broome v Cassell & Co Ltd [1972] AC 1027
- Conway v Rimmer [1968] AC 910
- Davis v Johnson [1979] AC 264
- Kleinwort Benson Ltd v Lincoln City Council [1999] 2 AC 349
- Knauer v Ministry of Justice [2016] UKSC 9, [2016] AC 908
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This summary is for study and revision and is not legal advice. Although our case summaries are checked for accuracy, we do not guarantee that they are free from errors or omissions. Always read the full judgment for the court's reasoning.
