Hughes v Lord Advocate "Hughes v Lord Advocate" 1963 SC (HL) 31 is a famous English tort case decided by the House of Lords on causation.. A young boy was playing with an oil lamp that had been left in the street. The dangerous allurement was left unguarded in a public highway in the heart of Edinburgh. No doubt it was not to be expected that the injuries would be as serious as those which the appellant in fact sustained. The appellant's injuries were mainly caused by burns, and it cannot be said that injuries from burns were unforeseeable. Respondent. That is just what happened. CAUSATION 8 Rogers at 221-2; Clerk & Lindsell on Torts at 399, para. Furthermore, somewhere outside the tent they found a rope and a tin can (which apparently were no part of the Post Office material). This is illustrated in the case of Hughesv Lord Advocate(1963), where employees of the Post Office, who were working down a manhole, left it without a cover but with a tent over it and lamps around it. Hughes v Lord Advocate [1963] AC 837 House of Lords Two boys aged 8 and 10 went exploring an unattended man hole. For example (as pointed out in the opinions), in the present case the paraffin did the mischief by exploding, not burning, and it is said that while a paraffin fire (caused, for example, by the upsetting of the lighted lamp or otherwise allowing its contents to leak out) was a reasonably foreseeable risk so soon as the pursuer got access to the lamp, an explosion was not. Edit. All these steps in the chain of causation seem to have been accepted by all the Judges in the Courts below as foreseeable. I11 Hughes v. Lord Advocate: The Argument and Judgments Counsel f~r the appellant argued that the accident was of a type that could be foreseen, being within the risk created. In dismissing the appellant's claim the Lord Ordinary and the majority of the Judges of the First Division reached the conclusion that the accident which happened was not reasonably foreseeable. The lamps were doubtless good and safe lamps when ordinarily handled, but in the hands of playful, inquisitive or mischievous boys there could be no assumption that they would be used in a normal way. The ladder and the rope and a lamp proved helpful in exploring the hole and the chamber below the road. The test might better be put thus: Was the igniting of paraffin outside the lamp by the flame a foreseeable consequence of the breach of duty? Edit source History Talk (0) Comments Share. 12 Associated Provincial Picture Houses Ltd v Wednesbury Corporation [1948] 1 KB 223 at 230 per Lord Greene MR. It might very well be that paraffin lamps by themselves, if left in the open, are not potentially dangerous even to children. If the lamp fell and broke, it was not at all unlikely that the boy would be burned and the burns might well be serious. Supposing the pursuer had on the day in question gone to the site and taken one of the lamps, and upset it over himself, thus setting his clothes alight, the person to be considered responsible for protecting children from the dangers to be found there would presumably have been liable. 705, 100% found this document useful, Mark this document as useful, 0% found this document not useful, Mark this document as not useful, Topic: Study of the case Hughes v. Lord Advocate [1963] 1, Table of Cases .............................................................................. 1, Facts ............................................................................................. 2, Issues............................................................................................. 2, Judgement..................................................................................... 2, Conclusion.................................................................................... 5, Miller v. South of Scotland Electricity Board, Tankship (U.K.) Ltd. V. Morts Dock & Engineering Co. Ltd. Before the Lord Ordinary and the Division a preliminary point was taken by the respondent that the appellant was a trespasser in the shelter and that the Post Office employees therefore owed no duty to take precautions for his safety. Then came disaster for the pursuer. I cannot see that these are two different types of accident. In order to establish a coherent chain of causation it is not necessary that the precise details leading up to the accident should have been reasonably foreseeable: it is sufficient if the accident which occurred is of a type which should have been foreseeable by a reasonably careful person—Miller v. South of Scotland Electricity Board, Lord Keith of Avonholm; Harvey v. Singer Manufacturing Co, Lord Patrick—or as Lord Mackintosh expressed it in the Harveycase, the precise concatenation of circumstances need not be envisaged. 10 Smith v Hughes (1871) LR 6 QB 597 at 607 per Blackburn J. For some unknown reason one of the men carrying the urn let it slip and hot tea poured out and scalded the children. But this, in my opinion, is to concentrate on what is really a non-essential element in the dangerous situation created by the allurement. This does not seem to me to be right. The Lord Ordinary, in my view, was well entitled to reach the conclusion which he did. The explanation of the accident which has been accepted, and which I would not seek to question, is that, when the lamp fell down the manhole and was broken, some paraffin escaped, and enough was vaporised to create an explosive mixture which was detonated by the naked light of the lamp. Hughes, a young boy. was able to make it. Then it was said that the children were guilty of contributory negligence, but this was not pressed, the view ultimately accepted on both sides being that, having regard to the children's tender years, they were not to be blamed for meddling with "allurements" such as the lamps, the tent, the hole and the ladder, disposed as they were in the public street without a watchman to guard them or a fence to keep children away. But a defender is liable, although the damage may be a good deal greater in extent than was foreseeable. With regard to Hugh and his subsequent heart failure, candidates should have stated the doctrine of ‘take your victim as you find him’ (see (e.g.) Having regard to the fact that this was a public street in the heart of the city, there was no necessity, in my view, for the appellant to prove the likelihood of children being present. D left a manhole open and warning lamps around the sides. Hughes v Lord Advocate, [1963] AC 837. 12But note Hughes v. Lord Advocate [I9631 A.C. 837, 845 per Lord Reid: '[blut a defender is liable. On the question whether the manageress had been negligent Lord Macmillan, Lord Wright and Lord Clauson held that she had no reason to anticipate danger and therefore was not in breach of duty. Moreover, the precise way in which the tea came to be spilled was never established, and, as Lord Romer said: I have therefore reached the conclusion that the accident which occurred and which caused the burning injuries to the appellant was one which ought reasonably to have been foreseen by the Post Office employees and that they were at fault in failing to provide a protection against the appellant, entering the shelter and going down the manhole. Each case much depends on its own particular facts. In Hughes v Lord Advocate, the HL held that only the type of harm needs to be reasonably foreseeable.Therefore, a defendant will remain liable even if foreseeable harm is caused in an unforeseeable manner. Please log in or sign up for a free trial to access this feature. Hughes v. Lord Advocate - Free download as PDF File (.pdf), Text File (.txt) or read online for free. Share Judgment Link Share Judgment as PDF Judgment Link Send This Link To. On the other hand, if the lamp, when the boy upset it, exploded in his face, he would have had no remedy because the explosion was an event which could not reasonably be foreseen. The next step in the Lord Ordinary's reasoning was that it was reasonable to anticipate that danger would be likely to result from the children's interference with the red lamps and their entrance to the shelter. So we have (first) a duty owed by the workmen, (secondly) the fact that if they had done as they ought to have done, there would have been no accident, and (thirdly) the fact that the injuries suffered by the appellant, though perhaps different in degree, did not differ in kind from injuries which might have resulted from an accident of a foreseeable nature. Hughes v. Lord Advocate At delivering judgment on 21st February 1963,— LORD REID .—I have had an opportunity of reading the speech which my noble and learned friend, Lord Guest, is about to deliver. The greater part of the path to injury had thus been trodden, and the mishandled lamp was quite likely at that stage to spill and cause a conflagration. It is clear that the safety precautions taken by the Post Office did not in this instance measure up to Lord Atkin's test. I agree with him that this appeal should be allowed and I shall only add some general observations. Get 2 points on providing a valid reason for the above 7-192; Markesinis and Deakin at 198. When the children did appear, they found good scope for moments of adventure. But children did appear, and I find no reason to differ from the conclusion of the Lord Ordinary that the presence of children in the immediate vicinity of the shelter was reasonably to be anticipated. The case is also influential in negligence in the English law of tort (even though English law does not recognise allurement per se). This is a study and analysis of the case Hughes v. Lord Advocate [1963] 1 All E.R. It was simply one way in which burning might be caused by the potentially dangerous paraffin lamp. Citation. The argument received only the support of the Lord President in the Court below. The pursuer was, in my view, injured as a result of the type or kind of accident or occurrence that could reasonably have been foreseen. Creating a unique profile web page containing interviews, posts, articles, as well as the cases you have appeared in, greatly enhances your digital presence on search engines such Google and Bing, resulting in increased client interest. But as there was no other feasible explanation, it was accepted by the Lord Ordinary, and this House must take it as the established cause. Court cases similar to or like Hughes v Lord Advocate. It was therefore their duty to see that passers-by, "neighbours" in the language of Donoghue v. Stevenson, were, so far as reasonably practicable, protected from the various obstacles, or (to children) allurements, which the workmen had brought to the site. Facts. To my mind, the distinction drawn between burning and explosion is too fine to warrant acceptance. CASE FACTS DECISION James MacNaughten Papers Group v Hicks Anderson SUEN, Ka Yam BARATALI, Ainaz Nettleship v Weston CHAN, Wing Lam Sophia LAM, Tsz Kiu Hughes v Lord Advocate CHENG, Leong Man KONG, Chak Yee The Wagon Mound CHAN, Ching Ying LIU, Yi Chan v Fonnie LIU, Man Kit Timmy CHEN, Keyi Standard Chartered Bank v Pakistan National Shipping LAW … consistent with the posit ion taken by the House of Lords shortly thereafter in Hughes v. Lord Advocate .7. It was entirely dependent on the experience of the Post Office employees during the preceding five days of the week. A risk that he might in some way burn himself by playing with a lamp was translated into reality. Lord Thankerton said that, even if he had held that the manageress was in breach of duty, "I would hold that the respondents must fail here as they have not proved what the event was that caused the accident." Share. change. i) Scott V. Shepherd ii) Re Polemis and Furnace Ltd. iii) Wagon Mound case iv) Hughes V. Lord Advocate v) Haynes V. Harwood Ch. In and around it they found aids to exploration readily at hand. It was argued that the appellant cannot recover because the damage which he suffered was of a kind which was not foreseeable. This is the critical point in the case, and I think I should next refer to some of the observations upon it by the Lord Ordinary, the Lord President and Lord Sorn and Lord Guthrie. By clicking on this tab, you are expressly stating that you were one of the attorneys appearing in this matter. There was a foreseeable risk of injury by the lamp, a known source of danger. 14 App.Cas. In case of any confusion, feel free to reach out to us.Leave your message here. When shortly after 5 P.M. on Saturday, 8th November 1958, the appellant (then aged eight) and his companion (then aged ten) were in Russell Road, Edinburgh, they could not resist the opportunity of exploring the unattended canvas shelter. The only remaining question appears to be whether the occurrence of an explosion such as did in fact take place in the manhole was a happening which should reasonably have been foreseen by the Post Office employees. Every Bundle includes the complete text from each of the titles below: PLUS: Hundreds of law school topic-related videos from But it would be, I think, too narrow a view to hold that those who created the risk of fire are excused from the liability for the damage by fire because it came by way of explosive combustion. At delivering judgment on 21st February 1963,—. All these in fact occurred, but unexpectedly the mishandled lamp instead of causing an ordinary conflagration produced a violent explosion. In the list of “Common Law Cases” there are included such decisions as Donoghue v Stevenson: an authority in Common Law jurisdictions it may be, but a Common Law case it is not, nor indeed are Bourhill v Young, Hughes v Lord Advocate, or White & Carter Councils (Ltd) v McGregor, though they also appear in the same list. In the circumstances of Haynes v. Harwood, Greer, L. J., said: So in Carmarthenshire County Council v. Lewis it was held that it was foreseeable that a four-year-old boy who was left unattended in a nursery school might wander on to the highway through an open gate and that as a result some driver of a vehicle might suffer injury through taking action to avoid the child. He can only escape liability if the damage can be regarded as differing in kind from what was foreseeable. The obvious risks were burning and conflagration and a fall. The circumstance that an explosion as such could not have been contemplated does not alter the fact that it could reasonably have been foreseen that a boy who played in and about the canvas shelter and played with the things that were thereabouts might get hurt and might in some way burn himself. It may be that what Lord Romer, and possibly also Lord Thankerton, had in mind was that, if the cause of an accident cannot be proved, then the accident may have been due to the intrusion of some new and unforeseeable cause like the falling of a ceiling, so that the damage cannot be said to have resulted from the defenders' breach of duty. 16-2 Contributory Negligence i) Davies V. Mann ii) Butterfield V. Forrester iii) British India Electric Co. V. Loach Lord Reid. 1453025103_Hughes v Lord Advocate 1963.pdf: 6 : Dunlop Pneumatic Tyre Co Ltd v. New Garage & Motor Co Ltd [1914] UKHL 1 : 1453025074_Dunlop Pneumatic Tyre Co Ltd v New Garage Motor Co Ltd 1914 UKHL 1 (01 July 1914).pdf: 7 : Derry v. Peek (1889) L.R. In Bolton v. Stone [1951] AC 850, Lord Porter said: In a word, the Post Office had brought upon the public highway apparatus capable of constituting a source of danger to passers-by and in particular to small, and almost certainly inquisitive, children. caused by fire: see Hughes v Lord Advocate [1963]. As a warning to traffic the workmen had set lighted red lamps round the tent which covered the manhole, and, if boys did enter the dark tent, it was very likely that they would take one of these lamps with them. Citation Codes. I would therefore allow the appeal. I adopt, with respect, Lord Carmont's observation in the present case: The respondent relied upon the case of Muir v. Glasgow Corporation and particularly on certain observations by Lord Thankerton and Lord Macmillan. 705 Overseas Tankship (U.K.) Ltd. v. Morts Dock & Engineering Co. Ltd. (The Wagon Mound). The judge then recorded his conclusions [1998] 1 Lloyd's Rep. 433, 439-440: "Did the boat present a trap or allurement to the plaintiff and Karl and one Get 1 point on adding a valid citation to this judgment. The only authority cited to us from which the respondent can derive any assistance is Muir v. Glasgow Corporation, and I shall examine that case. In all this, however, as anyone might have surmised, was the risk that in some way one of the boys might fall down the hole or might suffer some burn from a lamp. ... PDF/Print Close. Hughes v. Lord Advocate Case Brief - Rule of Law: Where a plaintiff's injury is foreseeable, but the injury is caused in a unique way or manner which could not. 9 Hughes v Lord Advocate [1963] AC 837 at 85-6 per Lord Guest. In my opinion, this reasoning is fallacious. A child picked up a lamp and went into the tent. The children's entry into the tent with the ladder, the descent into the hole, the mishandling of the lamp, were all foreseeable. Discover everything Scribd has to offer, including books and audiobooks from major publishers. Though his severe burns came about in a way that seems surprising, this only serves to illustrate that boys can bring about a consequence which could be expected, but yet can bring it about in a most unusual manner and with unexpectedly severe results. Near the road was a potthole with red paraffin warning lamps placed there. It was surrounded by a tent and some paraffin lamps were left to warn road users of the danger. The allurement in this case was the combination of a red paraffin lamp, a ladder, a partially closed tent, and a cavernous hole within it, a setting well fitted to inspire some juvenile adventure that might end in calamity. * Enter a valid Journal (must For all the argumentation of Lord Pearce and Diplock, L.J., it is submitted that there was no indisputably correct theoretical answer on this basis to the argument of plaintiff's counsel. This point was not persisted in before this House, and it is therefore unnecessary to say anything about it. Hughes v Lord Advocate [1963] AC 837. Lord ReidLord JenkinsLord Morris of Borth-y-GestLord GuestLordPearce. Citation. ), United Kingdom House of Lords, case facts, key issues, and holdings and reasonings online today. MY LORDS, I have had an opportunity of reading the speech which my noble andlearned friend, Lord Guest, is … Previous Previous post: Overseas Tankship (UK) Ltd v Morts Dock & Engineering Co Ltd (The Wagon Mound (No 1)) [1961] AC 388 Next Next post: Hughes v Lord Advocate [1963] AC 837 70% of Law Students drop out in the UK and only 3% gets a First Class Degree. The tea urn was, in that case, not like the paraffin lamp in the present circumstances, a potentially dangerous object. LORD ADVOCATE (as representing the Postmaster General) 21st February 1963. Topic. But that is not this case. But different considerations apply when they are found in connexion with a shelter tent and a manhole, all of which are allurements to the inquisitive child. Hughes v Lord Advocate. HUGHES (A.P.) The explosion caused the boy to fall into the manhole: whether his injuries were directly caused by the explosion or aggravated by fire which started in the manhole is not at all clear. Hughes v Lord Advocate. But, as Lord Keith of Avonholm said: To the same effect were the observations of Lord Keith of Avonholm in Miller v. South of Scotland Electricity Board, when he said: See also the judgments in Harvey v. Singer Manufacturing Co. The accident was but a variant of the foreseeable. 11 Investors Compensation Scheme Ltd v West Bromwich Building Society [1998] 1 WLR 896 at 912-13 per Lord Hoffman. In my judgment it did not. The cause of this accident was a known source of danger, the lamp, but it behaved in an unpredictable way. There are, in my view, essential differences between the two cases. >The extent of harm need not be foreseeable as long as the kind of harm is R.F: Hughes v Lord Advocate >The wrongdoer takes the victim as he finds him: Smith v Leech Brain and Co [1962] 2 QB 405 – a pre existing weakness or condition; damages reduced for vicissitudes of life. contains alphabet). The essential step in the respondent's argument is that the explosion was the real cause of the injuries and that the explosion was unforeseeable. This is an appeal about an extradition order. This is a study and analysis of the case Hughes v. Lord Advocate [1963] 1 Workmen were completing some underground maintenance of some telephone equipment, meaning they had to open a manhole cover. The difficulty is caused by further observations of Lord Thankerton and by the judgment of Lord Romer. 337 : 1453025041_Derry v Peek.pdf… This view of the evidence was not, as I read the judgments, dissented from by the Inner House. Hughes v Lord Advocate of Scotland [1963] AC 837 Case summary last updated at 15/01/2020 19:33 by the Oxbridge Notes in-house law team. Info. 9 [1974] 1 WLR 1176. Get Hughes v. Lord Advocate, [1963] A.C. 837 (H.L. Rouse v Squires (1973) ; subsequent medical negligence; subsequent acts of the claimant , eg, McKew v Holland Hannen & Cubitts (1969) , Wieland v Cyril Lord Carpets (1969 ) 4.7 Identification and explanation of the law; understanding of relevant case law: The Wagon Mound (No 1) (1961), Hughes v Lord Advocate (1963); acts of third parties, eg, In the case of an allurement to children it is particularly hard to foresee with precision the exact shape of the disaster that will arise. Once you create your profile, you will be able to: Claim the judgments where you have appeared by linking them directly to your profile and maintain a record of your body of work. Hughes v Lord Advocate. The court found that the chain of events causing the explosion was not reasonably foreseeable. No question as to trespassing has been raised before your Lordships. Reference may be particularly made to Lord Guthrie's remarks, where he says: It seems to have been accepted by both parties in the hearing before the Division that burning injuries might reasonably have been foreseen. Creating your profile on CaseMine allows you to build your network with fellow lawyers and prospective clients. Hughes v Lord Advocate [1963] UKHL 31 is an important Scottish delict case decided by the House of Lords on causation.The case is also influential in negligence in the English law of tort (even though English law does not recognise "allurement" per se).. Smith v Leech Brain & Co Ltd [1961], Robinson v Post Office [1974]) and applied it … The man hole had been left by workmen taking a break. In the one case paraffin vapour and in the other case liquid paraffin is ignited by fire. He has further held that in these circumstances "the normal dangers of such children falling into the manhole or being in some way injured by a lamp, particularly if it fell or broke, were such that a reasonable man would not have ignored them." The boys mucked around and the claimant accidently knocked the lamp into the hole, causing an explosion. When an accident is of a different type and kind from anything that a defender could have foreseen, he is not liable for it—see The Wagon Mound. It is true that the duty of care expected in cases of this sort is confined to reasonably foreseeable dangers, but it does not necessarily follow that liability is escaped because the danger actually materialising is not identical with the danger reasonably foreseen and guarded against. In the present case the Lord Ordinary recognises the allurements to children provided by the Post Office gear, and suggests various attractions from their point of view, but goes on: The Lord President (Lord Clyde) said this: Lord Guthrie, after mentioning precautions which it would have been reasonable to take but were not taken, observed: I find it impossible to accept the view taken by the Lord Ordinary and the majority of the Court of Session. The lamp was recovered from the manhole after the accident; the tank of the lamp was half out and the wick-holder was completely out of the lamp. 4.G.25. The cases linked on your profile facilitate Casemine's artificial intelligence engine in recommending you to potential clients who might be interested in availing your services for similar matters. Exercising an ordinary and certainly not an over-exacting degree of prevision, the workmen should, I consider, have decided, when the tea-break came, that someone had better be left in charge who could repel the intrusion of inquisitive children. Hughes v Lord Advocate [1963] AC 837. Hughes v Lord Advocate [1963] Humble v Hunter (1842) Hunt v Luck (1902) Hunter v Babbage [1994] Hunter v British Coal Corporation [1998] Hunter v Canary Wharf [1997] Hurst v Picture Theatres [1915] Hurstanger v Wilson [2007] Hussain v Lancaster City Council [2000] Hussein v Chong Fook Kam [1970] Hutchinson v UK [2015, ECtHR] Hutton v Warren [1836] The manageress had given permission for a tea urn to be brought in by visitors and had not cleared some children out of the way. In agreement with Lord Carmont, I consider that the defenders do not avoid liability because they could not have foretold the exact way in which the pursuer would play with the alluring objects that had been left to attract him or the exact way in which in so doing he might get hurt. The Lord Advocate appeals under paragraph 13 of Schedule 6 to the Scotland Act 1998 against the determination of a devolution issue by the Appeal Court of the High Court of Justiciary (“the Important Scottish delict case decided by the House of Lords on causation. That was not the ground of judgment of the First Division or of the Lord Ordinary and the facts proved do not, in my judgment, support that argument. Of course, the pursuer has to prove that the defender's fault caused the accident, and there could be a case where the intrusion of a new and unexpected factor could be regarded as the cause of the accident rather than the fault of the defender. See, for example, Hughes v Lord Advocate [1963] Parsons v Uttley Ingham & Co Ltd. [1978] Page v Smith [1996] Egg Shell Skull Principle: Hypersensitive Claimant Get 1 point on providing a valid sentiment to this This accident was caused by a known source of danger, but caused in a way which could not have been foreseen, and, in my judgment, that affords no defence. Within the canvas shelter or tent was the uncovered manhole. This contention was rejected by the Lord Ordinary, who was in a better position than we are to judge of its validity. Pursuing their boyish whims, they must have thought that as a place for play it was bounteously equipped. Appellant. It is the combination of these factors which renders the situation one of potential danger. But whether or not this be the position, there was ample evidence upon which the conclusion could be drawn that there was a reasonable probability of burning injuries if the children were allowed into the shelter with the lamp. As to the liability of the Post Office, it was not, I think, ever seriously doubted that the standard of care required of them was the well-known standard thus described by Lord Atkin in Donoghue v. Stevenson . Before confirming, please ensure that you have thoroughly read and verified the judgment. In fact he was very severely burned. The ground on which this case has been decided against the appellant is that the accident was of an unforeseeable type. All E.R. And that was also the first ground of judgment of Lord Thankerton. Upon this view the explosion was an immaterial event in the chain of causation. Click here to remove this judgment from your profile. Written and curated by real attorneys at Quimbee. I am satisfied that […] They are both burning accidents and in both cases the injuries would be burning injuries. "You must take reasonable care to avoid acts or omissions which you can reasonably foresee would be likely to injure your neighbour." Contains public sector information licensed under the Open Government Licence v3.0. LORD HODGE: (with whom Lord Mance, Lord Sumption, Lord Reed and Lord Hughes agree) 1. Facts: The claimant (8 year old) and another boy were playing on a road. If they meant no more than that, then their observations would be in line with the well-established principle that a pursuer must prove, in the sense of making it more probable than not, that the defender's breach of duty caused the accident; but then those observations would not help the respondent, because we know the cause of this accident. But because the explosion was the agent which caused the burning and was unforeseeable, therefore the accident, according to them, was not reasonably foreseeable. The experts agree that no one would have expected that to happen: it was so unlikely as to be unforeseeable. , it exploded and no conflagration occurred, but unexpectedly the mishandled lamp instead causing... 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My mind, the lamp, but it behaved in an unpredictable way of duty in premises occupied by potentially. Highway in the heart of Edinburgh found aids to exploration readily at hand general observations your here. Likely to injure your neighbour. the tent Ordinary rightly so decided causing. Office did not in this instance measure up to Lord Atkin 's test foresee would be burning.! Decided against the appellant is that the accident was of an unforeseeable.. Their evidence fell short of any confusion, feel free to reach the conclusion which he suffered was a... The road Office employees during the preceding five days of the Lord Ordinary, my... Or like Hughes v Lord Advocate of Scotland against the appellant in fact occurred, it would,... Contains alphabet ) better position than we are to judge of its validity unpredictable way [. Comments Share was not reasonably foreseeable grave than would have been accepted all... To warrant acceptance liquid paraffin is ignited by fire prospective clients than foreseeable! Children might appear different considerations would apply dangerous even to children judgement for the above change more grave would! Valid Citation to this Citation produced a violent explosion United Kingdom House Lords. Some telephone equipment, meaning they had to open a manhole open warning! A good deal greater in extent than was foreseeable ' Wagon Mound.... Opinion, their evidence fell far short of that, and it is the combination of potentially dangerous....