John Watson, Ltd v. Brown [1914] UKHL 492 (28 April 1914)

John Watson, Ltd v. Brown [1914] UKHL 492 (28 April 1914)

Death from pneumonia following a chill caused by abnormal exposure to cold air, itself a direct result of a workplace accident (wreck in mine shaft), is a personal injury by accident arising out of and in the course of employment under the Workmen's Compensation Act 1906, and is compensable even in the absence of physical impact.

Citation
[1914] UKHL 492
Parties
Appellant: John Watson, Limited; Respondent: Brown
Jurisdiction
United Kingdom
Judgment Date
28 April 1914
Procedural Posture
Appeal / House of Lords Judgment on Appeal From Second Division, Court of Session, Scotland
Outcome
Appeal allowed; interlocutor of Second Division reversed; award of arbitrator restored.
Legal Topics
Workmen's Compensation, Causation, Accident Arising Out of Employment, Proximate Cause, Personal Injury by Accident
Labour Law Tort Law Workmen's Compensation Causation Accident Arising Out of Employment Proximate Cause Personal Injury by Accident

Case Brief

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Parties

John Watson, Limited

Appellant

Brown

Respondent

Procedural Posture

Appeal / House of Lords Judgment on Appeal From Second Division, Court of Session, Scotland

Legal Issues

  1. 1 Whether death from pneumonia following a chill caused by abnormal exposure due to a workplace accident is compensable under the Workmen's Compensation Act 1906
  2. 2 Whether the chain of causation between the workplace accident and the resulting death was sufficient for compensation
  3. 3 Whether physical impact is necessary for compensation under the Act

Ratio Decidendi

Death from pneumonia following a chill caused by abnormal exposure to cold air, itself a direct result of a workplace accident (wreck in mine shaft), is a personal injury by accident arising out of and in the course of employment under the Workmen's Compensation Act 1906, and is compensable even in the absence of physical impact.

Court Disposition

Appeal allowed; interlocutor of Second Division reversed; award of arbitrator restored.

Orders

  • Award of compensation to appellant restored.
  • Respondents to pay costs.