John Watson Ltd v Brown: HL 28 Apr 1914

In consequence of a wreck in one of the shafts of a mine the miners were ordered to the surface. Those accustomed to ascend by the damaged shaft were directed to ascend by another shaft. They were detained an hour and a-half waiting until this shaft was free, the miners accustomed to use it being taken up first. While waiting they in their heated state were exposed to a downdraught of cold air. One of them caught a chill, upon which pneumonia supervened and he died. The arbiter in a claim for compensation found that his death was due to accident arising out of the employment. Held (rev. judgment of the Second Division) that the arbiter’s finding was right.


Lord Dunedin, Lord Kinnear, Lord Atkinson, Lord Shaw, and Lord Parmoor


[1914] UKHL 492, 51 SLR 492




Workmen’s Compensation Act 1906



Personal Injury, Health and Safety

Updated: 26 April 2022; Ref: scu.620713