Century Insurance v Northern Ireland RTB [1942] AC 509

House of Lords

Basic Facts: An employee, X, was delivering petrol for his employer, D. While X was connecting the delivery pipe to a garage, he lit a cigarette and carelessly discarded the match near the petrol tanker, resulting in a massive explosion that caused significant damage to nearby cars and houses.

Issue for the Court: What constitutes an act "within the course of employment"?

Held by Viscount Simon LC and Lord Romer:

• The court could not exclude the careless act from being within the course of employment.

• X was serving his employer by connecting the pipe and delivering the petrol.

• Although lighting the cigarette was a careless and unwise act, it occurred while X was engaged in his duties.

• The broader perspective must be considered; X’s actions were done in the course of his employment.