Doughty v. Turner Manufacturing Co., Ltd.
England and Wales Court of Appeals
1 Q.B. 1 (1964)
Doughty (plaintiff) sued his employer, Turner Manufacturing Company Limited (Turner) (defendant), for the burns he sustained when hot molten metal from a cauldron exploded onto him. Turner’s cauldrons had been in use throughout England and the United States for 20 years. Doughty's accident occurred when a worker accidentally knocked the cauldron's compound asbestos concrete lid off, causing it to slip into the mixture. Trial evidence suggested there was no splash when the lid entered the mixture and no immediate injuries to the bystanders. In fact, two workers approached the cauldron to watch the lid as it slipped beneath the surface of the mixture. One or two minutes later the mixture exploded and thrust molten metal onto Doughty, leaving him severely burned. The evidence also showed that, prior to the accident, no one supposed the immersion of an asbestos concrete compound in a molten metal mixture could lead to an explosion. However, subsequent testing showed that an asbestos concrete compound, if immersed in a molten metal mixture, will release water and the resulting chemical reaction will cause the mixture to explode. The trial judge ruled in Doughty's favor. Even though Turner reasonably could not have foreseen the explosive consequences of immersing the asbestos concrete compound in the molten metal mixture, the judge said Turner should have known: (1) the escape of any molten metal mixture from the cauldron, for example by splashing, could burn bystanders, and (2) some foreign substances, if immersed in the mixture, could cause the mixture to explode. Therefore, Turner should have taken precautions to prevent splashes and explosions, and Turner's negligent failure to do so made Turner liable for Doughty's injuries. Turner appealed to the England and Wales Court of Appeals.
Rule of Law
Holding and Reasoning (Pearce, J.)
Concurrence (Diplock, J.)
Concurrence (Harman, J.)
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