Ratio Decidendi
Where a non-tortious supervening event (such as a naturally occurring illness) overtakes the original injury and would have produced the same disability regardless, the first tortfeasor's liability is limited to the period before the supervening event.
Fapte
Jobling slipped at work due to his employer's negligence in 1973, injuring his back. In 1976, before the trial, he developed an unrelated spinal condition (myelopathy) that rendered him totally unfit for work regardless of the original injury.
Rezumatul hotărârii
The House of Lords held that the employer's liability was limited to the period 1973-1976. The myelopathy was a fact of life — a vicissitude — that should be taken into account. It distinguished Baker v Willoughby on the basis that a tortious act should be treated differently from a natural event.
Citate cheie
"The question is essentially a practical one, and in my opinion a practical answer should be given to it."
— Lord Bridge
Tratament ulterior
Distinguishes Baker v Willoughby for natural supervening events. Applied in subsequent cases on vicissitudes of life.