Weld-Blundell v Stephens: HL 1920

The plaintiff had been successfully sued for a libel contained in a document which he had supplied to his accountant.
Held: He could not recover the damages he had had to pay to the defamed party from his accountant, who had negligently left the document about so that it came to the former’s attention.
Lord Sumner said: ‘In general, even though A is in fault, he is not responsible for injury to C which B, a stranger to him, deliberately chooses to do. Though A may have given the occasion for B’s mischievous activity, B then becomes a new and independent cause.’
References: [1920] AC 956
Judges: Lord Sumner
Jurisdiction: England and Wales
This case cites:

  • Appeal from – Weld-Blundell v Stephens CA 1919
    The exception to the obligation not to disclose confidential information is limited to the proposed or contemplated commission of a crime or a civil wrong. . .
    ([1919] 1 KB 520)

This case is cited by:

  • Cited – Stansbiev Troman CA 1948
    A decorator working alone in a house went out to buy wallpaper and left the front door unlocked. He was held liable for the loss caused by a thief who entered while he was away. For the purpose of attributing liability to the thief (e.g. in a . .
    ([1948] 2 KB 48)
  • Cited – Empress Car Company (Abertillery) Ltd v National Rivers Authority HL 22-Jan-1998
    A diesel tank was in a yard which drained into a river. It was surrounded by a bund to contain spillage, but that protection was over ridden by an extension pipe from the tank to a drum outside the bund. Someone opened a tap on that pipe so that . .
    (Gazette 26-Feb-98, Times 09-Feb-98, Gazette 25-Mar-98, , , [1998] 2 WLR 350, [1998] UKHL 5, [1999] 2 AC 22, [1998] 1 All ER 481)
  • Cited – Les Laboratoires Servier and Another v Apotex Inc and Others SC 29-Oct-2014
    Ex turpi causa explained
    The parties had disputed the validity a patent and the production of infringing preparations. The english patent had failed and damages were to be awarded, but a Canadian patent remained the defendant now challenged the calculation of damages for . .
    (, [2014] UKSC 55, [2015] 1 AC 430, [2014] WLR(D) 452, [2014] BUS LR 1217, [2014] 3 WLR 1257, , , UKSC 2012/0158, , , , [2015] 1 All ER 671, [2015] RPC 10)

These lists may be incomplete.
Last Update: 27 November 2020; Ref: scu.190105