판결 이유
Once some damage was foreseeable from the defendant's negligent act, the defendant was liable for all direct consequences, however unforeseeable. This is the 'directness' test of remoteness.
사실관계
Stevedores negligently dropped a plank into the hold of a ship. The plank caused a spark which ignited petrol vapour, destroying the ship. It was foreseeable that dropping the plank might cause some damage, but not fire.
판결 요약
The Court of Appeal held that the charterers were liable for the fire damage. Once some damage (e.g., denting) was foreseeable, they were liable for all direct consequences, regardless of whether the specific type of damage (fire) was foreseeable.
주요 인용문
"Once the act is negligent, the fact that its exact operation was not foreseen is immaterial."
— Bankes LJ
후속 처리
Overruled by The Wagon Mound (No 1) [1961], which replaced the directness test with the reasonable foreseeability test for remoteness.