Smithurst v Sealant Construction Services Ltd

Smithurst v Sealant Construction Services Ltd

The judge was wrong to treat the issue as one of causation rather than assessment of damages, but the acceleration approach to damages was permissible and fairly reflected the medical evidence; the appeal is dismissed.

Parties
Claimant/appellant: Mark Simon Smithurst; Defendant/respondent: Sealant Construction Services Ltd
Jurisdiction
England and Wales
Judgment Date
03 November 2011
Procedural Posture
Personal Injury Appeal / Appeal From Assessment of Damages After Liability Admitted
Outcome
Appeal dismissed
Legal Topics
Causation, Assessment of Damages, Acceleration Principle, Contributory Negligence

Case Brief

Summary, issues, holding and outcome

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Parties

Mark Simon Smithurst

Claimant/appellant

Sealant Construction Services Ltd

Defendant/respondent

Procedural Posture

Personal Injury Appeal / Appeal From Assessment of Damages After Liability Admitted

  1. 1 Whether the trial judge erred in applying the 'but for' test of causation rather than assessing the risk of future injury for damages purposes
  2. 2 Whether the acceleration approach to damages was appropriate given the medical evidence

Ratio Decidendi

The judge was wrong to treat the issue as one of causation rather than assessment of damages, but the acceleration approach to damages was permissible and fairly reflected the medical evidence; the appeal is dismissed.

Court Disposition

Appeal dismissed

Orders

  • Assessment of damages to proceed on the basis that the accident accelerated the claimant's condition by two years.