Watson v British Boxing Board of Control [2001] QB 134

Facts

• Michael Watson, a professional boxer, suffered severe, life-threatening brain injuries during a 1991 match against Chris Eubank.
• Watson required extensive medical treatment and rehabilitation following the event.
• The British Boxing Board of Control (BBBC) was responsible for regulating professional boxing in the UK, including setting rules regarding medical care at events.
• Watson argued that BBBC failed to provide immediate and adequate medical attention and resuscitation equipment during the match, contributing to the severity of his injuries.
• The primary issue concerned whether BBBC had a duty to ensure sufficient medical facilities and personnel were present at the event and whether a breach of such duty caused further harm to Watson.

Issues

1. Whether the BBBC owed a duty of care to Michael Watson to provide adequate medical facilities and personnel at boxing events.
2. Whether the BBBC breached that duty by failing to ensure the presence of necessary medical care and equipment.
3. Whether the BBBC’s breach contributed materially to the severity of Watson’s injuries.

Decision

• The court found that the BBBC did owe a duty of care to boxers, arising from its regulatory role and knowledge of the risks naturally present in boxing.
• The BBBC breached this duty by failing to provide adequate medical facilities, personnel, and resuscitation equipment at the event.
• The court determined that the lack of immediate medical treatment at the event contributed to the severity of Watson’s injuries.
• The BBBC’s breach was a material cause of the harm Watson suffered.
• The case established accountability of sporting bodies for the safety protocols affecting participants.

Legal Principles

• The test for duty of care requires foreseeability of harm, proximity between parties, and that imposing a duty is fair, just, and reasonable, following Caparo Industries plc v Dickman [1990] 2 AC 605.
• Governing bodies that assume responsibility for setting rules and standards for participant safety may owe a duty of care to those participants.
• A breach occurs where there is failure to meet reasonable standards in providing for participant safety, and causation must be proven between the breach and the injury.
• The duty covers ensuring adequate medical protocols, equipment, and trained personnel to address foreseeable risks associated with the activity.

Conclusion

Watson v British Boxing Board of Control [2001] QB 134 confirmed that sporting governing bodies owe participants a duty of care to provide adequate medical facilities at events, and that breach of this duty—if causing harm—can result in liability for injuries sustained during regulated sports activities.