“Tortfeasor liable for full damages despite victim's subsequent unrelated injury”
Baker was injured in a road accident caused by Willoughby's negligence, suffering a stiff left leg that reduced his earning capacity. Before the case came to trial, Baker was shot in the left leg during an unrelated armed robbery and had to have the leg amputated. Willoughby argued his liability should be reduced since Baker would have lost earning capacity anyway due to the amputation.
Whether a tortfeasor's liability for future loss of earnings is reduced when the victim subsequently suffers an unrelated injury to the same limb that would have caused similar loss.
The House of Lords held that Willoughby remained fully liable for the original injury and its consequences. The subsequent amputation did not break the chain of causation or reduce the damages payable for the original tort.
This case established important principles about concurrent causation and the scope of a tortfeasor's liability when multiple events contribute to a claimant's loss. It remains a leading authority on causation in negligence claims involving successive injuries.
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OSCOLA Citation
Baker v Willoughby [1970] AC 467 (HL)
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