Ronan v Sainsbury's Supermarkets Ltd & Anor

Ronan v Sainsbury's Supermarkets Ltd & Anor

The Court held that the claimant's past loss of earnings during university was attributable to the accident and recoverable, but any continuing future loss of earnings was not, as the claimant's career change to teaching was a free choice. Only a limited future loss (while catching up in career progression) and a Smith v Manchester award for handicap on the labour market were justified.

Parties
Claimant/appellant: Ronan; Defendant/respondent: Sainsbury’s Supermarkets Ltd and Anr
Jurisdiction
England and Wales
Judgment Date
06 July 2006
Procedural Posture
Civil Appeal / Appeal From Central London County Court on Quantum of Damages
Outcome
Appeal allowed in part
Legal Topics
Quantum of Damages, Loss of Earnings, Future Loss, Handicap on Labour Market, Causation
Personal Injury Tort Law Quantum of Damages Loss of Earnings Future Loss Handicap on Labour Market Causation

Case Brief

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Parties

Ronan

Claimant/appellant

Sainsbury’s Supermarkets Ltd and Anr

Defendant/respondent

Procedural Posture

Civil Appeal / Appeal From Central London County Court on Quantum of Damages

Legal Issues

  1. 1 Whether past loss of earnings during university was attributable to the accident or a voluntary career change
  2. 2 Whether future loss of earnings was attributable to the accident or a free choice
  3. 3 Appropriate quantification of damages for future loss and handicap on the labour market

Ratio Decidendi

The Court held that the claimant's past loss of earnings during university was attributable to the accident and recoverable, but any continuing future loss of earnings was not, as the claimant's career change to teaching was a free choice. Only a limited future loss (while catching up in career progression) and a Smith v Manchester award for handicap on the labour market were justified.

Court Disposition

Appeal allowed in part

Orders

  • Judge’s award of £50,000 for future loss quashed and replaced with £28,800: £12,000 for lost earnings while catching up, £1,800 for pension loss, £15,000 Smith v Manchester award
  • Judge’s award for past loss undisturbed