Tooth & Co Ltd v Tillyer [1956] HCA 49

Tooth & Co Ltd v Tillyer [1956] HCA 49

Section 64 of the Workers' Compensation Act only applies if the worker's injury is caused under circumstances creating a legal liability in some person other than the employer to pay damages. Because, both at common law and under statute, a wife cannot sue her husband in tort for personal injuries, no such liability arises and therefore the employer has no right of indemnity from the negligent spouse.

Jurisdiction
Australia
Procedural Posture
Application for Special Leave to Appeal / Application for Special Leave Refused
Outcome
Application for special leave refused.
Legal Topics
['statutory Interpretation' 'indemnity' "married Women's Legal Capacity" 'tort Liability Between Spouses']

Case Brief

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Procedural Posture

Application for Special Leave to Appeal / Application for Special Leave Refused

  1. 1 ["Whether s. 64 of the Workers' Compensation Act 1926-1954 (NSW) entitles an employer to indemnity from a worker's spouse when the worker's injury was caused by the spouse's negligence but no action in tort could be brought by one spouse against the other."]

Ratio Decidendi

Section 64 of the Workers' Compensation Act only applies if the worker's injury is caused under circumstances creating a legal liability in some person other than the employer to pay damages. Because, both at common law and under statute, a wife cannot sue her husband in tort for personal injuries, no such liability arises and therefore the employer has no right of indemnity from the negligent spouse.

Court Disposition

Application for special leave refused.

Orders

  • ['Application for special leave refused.']