What is the ratio in Wheat v Lacon?

The ratio is that 'occupier' for liability purposes means having sufficient degree of control over premises, not legal ownership. Multiple parties can be occupiers simultaneously if they exercise different aspects of control.

What did the court decide in Wheat v Lacon?

The House of Lords held that both the brewery owner and resident managers were occupiers, but neither was liable as the unlit stairs did not constitute a dangerous state of the premises.

Why is Wheat v Lacon important for occupiers' liability?

It established the fundamental test for determining who is an 'occupier' under the Occupiers' Liability Acts, focusing on factual control rather than legal ownership of premises.

What is the ratio in Wheat v Lacon?

The ratio is that 'occupier' for liability purposes means having sufficient degree of control over premises, not legal ownership. Multiple parties can be occupiers simultaneously if they exercise different aspects of control.

What did the court decide in Wheat v Lacon?

The House of Lords held that both the brewery owner and resident managers were occupiers, but neither was liable as the unlit stairs did not constitute a dangerous state of the premises.

Why is Wheat v Lacon important for occupiers' liability?

It established the fundamental test for determining who is an 'occupier' under the Occupiers' Liability Acts, focusing on factual control rather than legal ownership of premises.

Tort1 min read

Wheat v Lacon

[1966] AC 552House of Lords1966

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“House of Lords defines 'occupier' based on control not ownership”

Facts

The Lacons owned a pub and granted their manager a licence to live in the private quarters upstairs. A guest of the manager fell down an unlit staircase due to a missing handrail and died. The guest's widow sued both Lacon as brewery owners and the manager.

Issues

Who could be considered an 'occupier' for the purposes of occupiers' liability under the Occupiers' Liability Act 1957, and whether multiple occupiers could exist simultaneously.

Held

Both the brewery owners and the manager could potentially be occupiers, as occupation depends on having sufficient degree of control over premises. However, neither was liable on the facts as the danger was not reasonably foreseeable.

Significance

This case established the foundational test for determining occupier status in English tort law, moving away from technical legal concepts to practical control-based approach. It remains the leading authority on who qualifies as an occupier.

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OSCOLA Citation

Wheat v E Lacon & Co Ltd [1966] AC 552 (HL)

Tort LawOccupiers' Liability

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