Vowles v Evans [2003] EWCA Civ 318 (11 March 2003)

Vowles v Evans [2003] EWCA Civ 318 (11 March 2003)

A rugby referee, even in an amateur context, owes a duty of care to players to enforce safety rules; failure to ensure only suitably trained players participate in the front row constitutes a breach of that duty, and where such breach causes injury, liability arises.

Citation
[2003] EWCA Civ 318
Parties
Respondent: Richard Vowles; First Appellant: David Evans; Second Appellant: The Welsh Rugby Union Limited
Jurisdiction
England and Wales
Judgment Date
11 March 2003
Procedural Posture
Civil Appeal / Appeal From High Court Judgment
Outcome
Appeal dismissed
Legal Topics
Negligence, Duty of Care, Vicarious Liability, Personal Injury, Standard of Care, Causation, Breach of Duty
Tort Law Sports Law Negligence Duty of Care Vicarious Liability Personal Injury Standard of Care Causation +1 more

Case Brief

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Parties

Richard Vowles

Respondent

David Evans

First Appellant

The Welsh Rugby Union Limited

Second Appellant

Procedural Posture

Civil Appeal / Appeal From High Court Judgment

Legal Issues

  1. 1 Whether an amateur rugby referee owes a duty of care to players
  2. 2 Whether the referee breached that duty by permitting an unqualified player in the front row
  3. 3 Whether the breach caused the claimant's injury

Ratio Decidendi

A rugby referee, even in an amateur context, owes a duty of care to players to enforce safety rules; failure to ensure only suitably trained players participate in the front row constitutes a breach of that duty, and where such breach causes injury, liability arises.

Court Disposition

Appeal dismissed

Orders

  • Appellants to pay respondent's costs on the standard basis, subject to detailed assessment if not agreed.
  • Detailed assessment of respondent's costs pursuant to the Legal Aid Act 1998.