Corr v IBC Vehicles Ltd

Corr v IBC Vehicles Ltd

The employer's duty of care did not extend to preventing the deceased's suicide, as suicide was not a reasonably foreseeable consequence of the workplace accident. Damages for suicide are not recoverable as they fall outside the scope of the defendant's duty of care. The deceased's estate is entitled only to damages...

Source-derived case information.

Parties
Claimant: Eileen Corr (Administratrix of the Estate of Thomas Corr Deceased); Defendant: IBC Vehicles Ltd
Jurisdiction
England and Wales
Judgment Date
28 April 2005
Procedural Posture
Personal Injury and Fatal Accident Claim / Judgment
Outcome
Claim for damages relating to suicide dismissed; damages for accident injuries awarded.
Legal Topics
Duty of Care, Remoteness of Damage, Foreseeability, Psychiatric Injury, Suicide, Novus Actus Interveniens, Volenti Non Fit Injuria, Contributory Negligence
Tort Employment Law Duty of Care Remoteness of Damage Foreseeability Psychiatric Injury Suicide Novus Actus Interveniens +2 more

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Summary, issues, holding and outcome

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Parties

Eileen Corr (Administratrix of the Estate of Thomas Corr Deceased)

Claimant

IBC Vehicles Ltd

Defendant

Procedural Posture

Personal Injury and Fatal Accident Claim / Judgment

Legal Issues

  1. 1 Whether the employer's duty of care extends to preventing suicide of an employee injured at work
  2. 2 Whether suicide was a reasonably foreseeable consequence of the workplace accident
  3. 3 Whether damages for suicide are recoverable under the Law Reform (Miscellaneous Provisions) Act 1934 and Fatal Accidents Act 1976

Ratio Decidendi

The employer's duty of care did not extend to preventing the deceased's suicide, as suicide was not a reasonably foreseeable consequence of the workplace accident. Damages for suicide are not recoverable as they fall outside the scope of the defendant's duty of care. The deceased's estate is entitled only to damages attributable to the accident injuries.

Court Disposition

Claim for damages relating to suicide dismissed; damages for accident injuries awarded.

Orders

  • General damages of £45,000 awarded for personal injury; special damages to be agreed if they arise.