Hughes v Lord Advocate [1963] AC 837 (House of Lords) 

Basic Facts: D left an open manhole surrounded by paraffin lamps as a warning. An 8-year-old C took a lamp, dropped it into the manhole, causing an explosion due to the fumes, resulting in severe burns. 

Issue: Can a claim for damages be defeated if the extent of damage is not reasonably foreseeable? 

Held: Appeal allowed; Cā€™s injury was reasonably foreseeable.

  • Lord Reid: D was negligent in leaving the manhole open and unattended. It was foreseeable that children might play with the lamps and get burned. Even though the explosion was unforeseeable, the type of damage (burns) was foreseeable, so D is liable for all the resulting damage, not just the foreseeable extent. 

  • Lord Morris: The paraffin lamp was a dangerous object, and D breached their duty of care. The explosion, although distinct, was not too different from a foreseeable burn, and thus D is liable. 

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Hunter v Canary Wharf [1997] AC 655 (House of Lords) 

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Home Office v Dorset Yacht Co [1970] AC 1004