Woods v Multi-Sport Holdings Pty Ltd [2002] HCA 9

Woods v Multi-Sport Holdings Pty Ltd [2002] HCA 9

By majority, the High Court held that the respondent had not breached its duty of care by failing to provide helmets or issue warnings, as the risk of being struck by a ball—and consequent eye injury—was obvious to a reasonable participant, and the general practice did not require helmets, nor were they available or suitable for the sport at the time. The respondent's conduct was reasonable in the circumstances. The appeal was dismissed.

Parties
Appellant: Michael Brett Woods; Respondent: Multi-Sport Holdings Pty Ltd
Jurisdiction
Australia
Judgment Date
07 March 2002
Procedural Posture
Appeal / High Court of Australia, Judgment on Appeal From Full Court of the Supreme Court of Western Australia
Outcome
Appeal dismissed with costs (by majority).
Legal Topics
Negligence, Occupier's Liability, Duty of Care, Sporting Injuries, Obvious Risks, Industry Practise as to Standard of Care, Warnings, Protective Equipment, Causation, Voluntary Assumption of Risk
Tort Law Negligence Occupier's Liability Duty of Care Sporting Injuries Obvious Risks Industry Practise as to Standard of Care Warnings +3 more

Case Brief

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Parties

Michael Brett Woods

Appellant

Multi-Sport Holdings Pty Ltd

Respondent

Procedural Posture

Appeal / High Court of Australia, Judgment on Appeal From Full Court of the Supreme Court of Western Australia

Legal Issues

  1. 1 Whether the respondent breached its duty of care to the appellant by (a) failing to provide a protective helmet and (b) failing to warn of the danger of sustaining an eye injury while playing indoor cricket;
  2. 2 Whether the risk of eye injury was an inherent, obvious risk relieving the respondent of further duty;
  3. 3 Whether industry rules and practice regarding the use of protective headgear affect the standard of care required;

Ratio Decidendi

By majority, the High Court held that the respondent had not breached its duty of care by failing to provide helmets or issue warnings, as the risk of being struck by a ball—and consequent eye injury—was obvious to a reasonable participant, and the general practice did not require helmets, nor were they available or suitable for the sport at the time. The respondent's conduct was reasonable in the circumstances. The appeal was dismissed.

Court Disposition

Appeal dismissed with costs (by majority).

Orders

  • Appeal dismissed with costs.