## Facts

- Mr. Jobling, a butcher, suffered a back injury in 1973 at work due to his employer Associated Dairies' negligence, resulting in partial disability and a 50% reduction in earnings.
- In 1976, before trial, Mr. Jobling developed myelopathy, a separate spinal disease unrelated to the workplace injury, leading to complete disability.
- The key issue was how the onset of myelopathy impacted the employer's liability for loss of earnings.
- Lower courts applied the principle from Baker v Willoughby, potentially holding the employer liable for losses beyond the onset of the disease.
- Associated Dairies appealed, and the matter was considered by the House of Lords.

## Issues

1. Whether the defendant employer should be liable for the claimant’s complete future loss of earnings after the supervening onset of a natural, non-tortious illness.
2. How a non-tortious supervening event, as opposed to a subsequent tort, affects the assessment of damages for loss of earnings.
3. Whether the approach in Baker v Willoughby should apply when the supervening event is a natural occurrence rather than an additional tort.

## Decision

- The House of Lords held that Associated Dairies was liable only for the loss of earnings suffered between the initial workplace injury and the onset of myelopathy in 1976.
- The supervening illness (myelopathy) was a normal vicissitude of life and must be considered when awarding compensation.
- The chain of causation was broken by the unrelated disease, relieving the defendant of liability for further losses beyond that point.
- The court distinguished the case from Baker v Willoughby, holding that the same principle does not apply where the supervening event is non-tortious.
- Compensation was limited to what Mr. Jobling would have earned absent the unrelated disease.

## Legal Principles

- A tortfeasor’s liability for damages is limited where a non-tortious, naturally occurring supervening event breaks the causal chain.
- The “vicissitudes of life” doctrine requires courts to consider foreseeable but non-culpable events, such as unrelated illnesses, which may independently impact a claimant’s earning capacity.
- The assessment of damages should reflect only the losses attributable to the defendant’s negligence up to the point when a supervening, non-tortious event incapacitates the claimant.
- The approach in Baker v Willoughby—where liability for full loss continues after a second tort—does not extend to subsequent natural events; liability is curtailed from the onset of the unrelated, disabling condition.

## Conclusion

Jobling v Associated Dairies [1982] AC 794 established that where a non-tortious supervening event, such as an illness, interrupts the consequences of a prior tort, the original tortfeasor is liable only for the loss up to that event, marking an important distinction in the law of causation and assessment of damages.
