Bett v. Dalmeny Oil Co., Ltd [1905] ScotLR 42_638 (17 June 1905)

Bett v. Dalmeny Oil Co., Ltd [1905] ScotLR 42_638 (17 June 1905)

The statutory duty to make the mine roof secure under the Coal Mines Regulation Act 1887 is absolute and cannot be avoided by invoking the doctrine of common employment. The employer's neglect after being warned by a prior roof fall constitutes inexcusable negligence and breach of statutory duty.

Citation
[1905] ScotLR 42_638
Parties
Pursuer: Robert Bett; Defender: Dalmeny Oil Company, Limited
Jurisdiction
Scotland
Judgment Date
17 June 1905
Procedural Posture
Personal Injury Action / Motion for New Trial After Jury Verdict
Outcome
rule discharged; verdict for pursuer upheld
Legal Topics
Negligence, Statutory Duty, Common Employment, Coal Mines Regulation Act 1887

Case Brief

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Parties

Robert Bett

Pursuer

Dalmeny Oil Company, Limited

Defender

Procedural Posture

Personal Injury Action / Motion for New Trial After Jury Verdict

  1. 1 Is the doctrine of common employment a valid defence to breach of statutory duty under the Coal Mines Regulation Act 1887?
  2. 2 Did the employer breach its statutory and common law duty to make the mine roof secure?

Ratio Decidendi

The statutory duty to make the mine roof secure under the Coal Mines Regulation Act 1887 is absolute and cannot be avoided by invoking the doctrine of common employment. The employer's neglect after being warned by a prior roof fall constitutes inexcusable negligence and breach of statutory duty.

Court Disposition

rule discharged; verdict for pursuer upheld

Orders

  • motion for new trial refused
  • damages of £250 awarded to pursuer