Church v Dugdale and Adams Ltd: CA 1929

The court was asked whether an employer was responsible in law to a workman who having been injured so as to leave the employer liable under the Workers’ Compensation Acts, later committed suicide.
Held: Lord Hamworth MR said: ‘It is necessary to find not merely that there has been suicide, not merely at the time of the suicide that there was some depression and some delusions, but you must find that the condition of the man was such that the accident disabled him from exercising a judgment, and in that sense caused the accident. If you find merely that in consequence of the accident he is brooding in fear of poverty, or in distress, or in a mental condition which is consistent with the condition of a person not suffering from the accident, there you do not find and are not entitled to draw the inference that his mind has become so unhinged as to dethrone his power of volition and in that sense there is no proof and no necessary connection between the accident and the suicide.’

Lord Hamworth MR
(1929) 22 BWCC 444
England and Wales
Cited by:
CitedCorr v IBC Vehicles Ltd CA 31-Mar-2006
The deceased had suffered a head injury whilst working for the defendant. In addition to severe physical consequences he suffered post-traumatic stress, became more and more depressed, and then committed suicide six years later. The claimant . .

Lists of cited by and citing cases may be incomplete.


Updated: 22 January 2022; Ref: scu.240042