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Hughes v. Lord Advocate

United Kingdom House of Lords
[1963] A.C. 837 (H.L.)

Hughes v. Lord Advocate


Post Office employees were working in a manhole, underneath the street. The employees took a break and left the manhole open, unguarded, and enclosed by kerosene lanterns. Hughes (plaintiff) and another young boy entered the worksite and managed to knock a lantern into the manhole. After the lantern fell, its kerosene gas contacted the lantern flame causing an explosion and a fire. The explosion caused Hughes to fall into the manhole, where he suffered burns on his body. Hughes brought a negligence claim against the Lord Advocate (defendant), who represented the Post Office employees. The trial court ruled in favor of the Lord Advocate, holding that while burn injuries were foreseeable, the manner in which Hughes’ burns occurred was not a foreseeable cause of harm.

Rule of Law


Holding and Reasoning (Guest, L.)

Concurrence (Pearce, L.)

Concurrence (Reid, L.)

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