“Tortfeasor not liable for losses from unrelated supervening illness”
Jobling suffered a back injury at work due to his employer's negligence in 1973, reducing his earning capacity by 50%. In 1976, he developed an unrelated spinal condition (myelopathy) that would have rendered him unfit for work regardless of the original injury. The question arose whether the employer remained liable for loss of earnings after 1976.
Whether a tortfeasor remains liable for continuing losses when the claimant subsequently develops an unrelated condition that would independently have caused the same loss.
The House of Lords held that the employer was not liable for loss of earnings after the onset of the unrelated spinal condition, as the claimant would have suffered the same loss regardless of the original tort.
This case is fundamental to understanding causation in negligence, particularly regarding supervening events and the limits of a tortfeasor's liability. It clarified that defendants are only liable for losses actually caused by their negligence, not losses that would have occurred anyway.
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OSCOLA Citation
Jobling v Associated Dairies [1982] AC 794 (HL)
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