Facts
- The case involved Mr. Harrison, a train guard, who attempted to rescue a passenger falling from a moving train.
- The incident was caused by the premature departure of the train, allegedly due to the negligence of another railway employee.
- As a result of his rescue attempt, Mr. Harrison also fell and suffered injuries.
Issues
- Whether the defendant’s negligence that led to the passenger's fall also foreseeably created a situation likely to induce a rescue attempt.
- Whether Mr. Harrison’s actions as a rescuer were reasonable in the circumstances or so reckless as to break the chain of causation.
- Whether the defendant was liable for injuries sustained by Mr. Harrison during the rescue attempt.
Decision
- The Court of Appeal held that the defendant’s negligence in allowing the train to depart early created a foreseeable risk necessitating rescue.
- It was determined that Mr. Harrison’s intervention as a rescuer was reasonable in the context of the situation.
- The defendant was found liable for Mr. Harrison's injuries, as the chain of causation remained unbroken by the rescue attempt.
Legal Principles
- Where a defendant's negligence creates a danger, a rescue attempt by a third party is a foreseeable and natural response ("danger invites rescue" doctrine).
- Liability can arise for injuries to rescuers if the original negligence created the danger and the rescuer’s actions were reasonable.
- Reckless or unnecessarily hazardous intervention by a rescuer may break the chain of causation and relieve the defendant of liability.
- The case solidifies the application of the "danger invites rescue" principle in English law, confirming the criteria of foreseeability and reasonableness of the rescuer’s conduct.
Conclusion
Harrison v British Railways Board established that a defendant may be held liable for injuries suffered by a rescuer if their negligence created a foreseeable danger and the rescuer’s actions were reasonable, significantly shaping the legal approach to causation in rescue situations.