Jobling v Associated Dairies [1982] AC 794

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.