Calvert v William Hill Credit Ltd [2008] EWCA Civ 1427

Facts

  • Mr. Calvert entered into a self-exclusion agreement with William Hill Credit Ltd, a well-known bookmaker, to prevent himself from placing bets due to his gambling problem.
  • William Hill failed to enforce the self-exclusion, allowing Mr. Calvert to place large bets.
  • Mr. Calvert sustained significant financial losses as a result of continued gambling.
  • Mr. Calvert brought a negligence claim against William Hill, alleging breach of duty for failing to enforce the self-exclusion and claiming this caused his losses.

Issues

  1. Whether William Hill owed and breached a duty of care to Mr. Calvert by failing to enforce the self-exclusion agreement.
  2. Whether Mr. Calvert’s voluntary gambling constituted a new intervening act, breaking the chain of causation and absolving William Hill of liability.
  3. Whether Mr. Calvert’s actions amounted to contributory negligence, thereby reducing or extinguishing William Hill’s liability.

Decision

  • The Court of Appeal found that William Hill breached its duty by failing to enforce the self-exclusion agreement.
  • However, Mr. Calvert’s decision to gamble was a voluntary and independent act that broke the chain of causation between William Hill’s breach and the losses incurred.
  • The court also determined that Mr. Calvert’s actions amounted to contributory negligence.
  • William Hill was not held liable for the claimant’s gambling losses due to the intervening voluntary actions of Mr. Calvert.

Legal Principles

  • Causation in negligence requires the defendant’s breach to be the proximate cause of the claimant’s loss.
  • A voluntary, independent act by the claimant (novus actus interveniens) can sever the chain of causation.
  • Contributory negligence arises where a claimant’s own conduct contributes to the loss, potentially limiting the defendant’s liability.
  • A claimant’s informed assumption of risk may preclude recovery, especially in inherently risky activities like gambling.
  • Effective enforcement of harm-minimization measures is important, but personal responsibility limits a defendant’s liability when a claimant acts voluntarily.

Conclusion

The Court of Appeal held that although William Hill breached its duty by not enforcing the self-exclusion agreement, Mr. Calvert’s voluntary decision to gamble severed the causal link, thereby barring recovery for his losses and affirming the limits of legal liability in cases involving voluntary participation in risky activities.

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