Calvert v William Hill Credit Ltd [2008]

Court: High Court

Facts: Graham Calvert, a successful greyhound trainer and pathological gambler, sued William Hill Credit Ltd for £2.1 million after the company failed to enforce its self-exclusion policy. Despite Calvert’s request to close his account and not reopen it, William Hill allowed him to continue betting for two weeks, during which he incurred substantial losses. Calvert claimed that due to the bookmaker’s negligence, he lost £2.1 million between June and December 2006.

Issue: The central issue was whether William Hill had breached its duty of care by failing to implement its self-exclusion policy effectively and if so, whether Calvert was entitled to recover his losses.

Held: The court found that William Hill had indeed failed in its duty of care due to significant weaknesses in its internal arrangements for enforcing self-exclusion. Despite this, Calvert’s claim for the £2,052,972.18 he lost was dismissed. The judge reasoned that Calvert would have likely incurred similar losses with other bookmakers, as he continued to gamble with other companies even after his William Hill accounts were closed. Furthermore, Calvert’s claim for personal injury damages also failed.

Key Judicial Statement: The judge emphasized the duty of bookmakers to enforce responsible gambling measures, stating that while William Hill had breached its duty of care, the causation of Calvert's losses was not sufficiently linked to the breach because of his continued gambling with other operators.

💡 LevelUpLaw: Calvert v William Hill Credit Ltd highlights the critical importance of bookmakers implementing and enforcing effective self-exclusion policies to protect individuals from excessive gambling. Although William Hill failed in its duty to enforce the self-exclusion, the case demonstrates that damages for gambling losses may not be recoverable if the claimant would have likely incurred similar losses elsewhere. It underscores the complex interplay between duty of care and personal responsibility in gambling-related cases.