Wattleworth v Goodwood Road Racing Company Ltd & Ors [2004] EWHC 140 (QB) (04 February 2004)

Wattleworth v Goodwood Road Racing Company Ltd & Ors [2004] EWHC 140 (QB) (04 February 2004)

Goodwood owed and did not breach its duty of care under the Occupiers' Liability Act 1957; the tyre barrier design was not negligent given prevailing standards and expert advice. The MSA and FIA did not owe a duty of care to Mr Wattleworth as their regulatory roles did not extend to individual safety warranties. Even if a duty had existed, there was no breach. Volenti and contributory negligence were not established on the facts. Accordingly, the claim fails against all defendants.

Citation
[2004] EWHC 140
Parties
Claimant: Elisabeth Ruth Wattleworth; First Defendant: Goodwood Road Racing Company Limited; Second Defendant: Royal Automobile Club Motor Sports Association Limited; Third Defendant: Federation Internationale de l'Automobile
Jurisdiction
England and Wales
Judgment Date
04 February 2004
Procedural Posture
Civil Negligence / Fatal Accident / Trial Judgment on Liability and Causation
Outcome
Claim dismissed
Legal Topics
Negligence, Duty of Care, Occupiers' Liability Act 1957, Causation, Volenti Non Fit Injuria, Contributory Negligence, Motor Sports Safety, Standard of Care, Liability of Regulatory Bodies
Tort Law Personal Injury Occupiers' Liability Sports Law Negligence Duty of Care Occupiers' Liability Act 1957 Causation +5 more

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Parties

Elisabeth Ruth Wattleworth

Claimant

Goodwood Road Racing Company Limited

First Defendant

Royal Automobile Club Motor Sports Association Limited

Second Defendant

Federation Internationale de l'Automobile

Third Defendant

Procedural Posture

Civil Negligence / Fatal Accident / Trial Judgment on Liability and Causation

Legal Issues

  1. 1 Whether Goodwood owed and breached a duty of care to Mr Wattleworth under the Occupiers' Liability Act 1957
  2. 2 Whether the MSA and/or FIA owed a duty of care in tort to users of the Goodwood circuit, including Mr Wattleworth
  3. 3 Whether any breach of duty by any defendant caused Mr Wattleworth's death

Ratio Decidendi

Goodwood owed and did not breach its duty of care under the Occupiers' Liability Act 1957; the tyre barrier design was not negligent given prevailing standards and expert advice. The MSA and FIA did not owe a duty of care to Mr Wattleworth as their regulatory roles did not extend to individual safety warranties. Even if a duty had existed, there was no breach. Volenti and contributory negligence were not established on the facts. Accordingly, the claim fails against all defendants.

Court Disposition

Claim dismissed

Orders

  • Claim against all defendants dismissed
  • Costs to be determined at a later hearing