Corr v IBC Vehicles Ltd [2008] 2 WLR 499 (HL)

Facts

• Mr. Corr suffered severe head injuries in a workplace accident due to the negligence of his employer, IBC Vehicles.
• As a result of the injury, Mr. Corr developed severe depression and psychological distress.
• Mr. Corr subsequently died by suicide.
• Mrs. Corr, the claimant and widow, brought an action against IBC Vehicles, arguing that the suicide was a direct result of the employer’s negligence.
• IBC Vehicles argued that the act of suicide was an intervening event that broke the chain of causation and raised the defense of volenti non fit injuria, asserting Mr. Corr had voluntarily accepted the risk.

Issues

1. Whether Mr. Corr's suicide broke the chain of causation initiated by the employer's negligence.
2. Whether the suicide was a reasonably foreseeable consequence of the initial workplace injury.
3. Whether the defense of volenti non fit injuria applied, given Mr. Corr's mental state following the accident.
4. How mental health conditions impact the assessment of causation and liability in negligence.

Decision

• The House of Lords held that Mr. Corr’s suicide did not break the chain of causation; it was a direct consequence of the employer’s negligence.
• Foreseeability of the precise method of harm (suicide) was not required; it was sufficient that depression was a foreseeable consequence of the original injury.
• The court rejected the volenti non fit injuria defense, as Mr. Corr’s actions were not entirely voluntary but were the result of a severe psychological condition attributable to the employer’s negligence.
• Injury to mental health caused by an initial negligent act was recognized as holding the same significance as physical harm for causation and liability.
• The case was distinguished from instances where the link between the negligent act and the resulting harm was too remote in time or circumstance, emphasizing the need for direct causal connection.

Legal Principles

• A defendant is liable for all reasonably foreseeable harm caused by their negligence, even if the precise manner in which it materializes is not foreseeable.
• The chain of causation remains intact when intervening acts, such as suicide, are themselves direct results of the defendant’s negligence.
• The defense of volenti non fit injuria does not apply if the claimant’s capacity for voluntary action is undermined by mental incapacity caused by the defendant’s wrongdoing.
• Mental health conditions resulting from negligence are to be treated as actionable harm for purposes of establishing liability.
• The proximity and causal potency of contributory factors are critical considerations in causation.

Conclusion

The House of Lords clarified that defendants remain liable for all foreseeable consequences of their negligence, including suicide resulting from depression caused by their actions, and that volenti non fit injuria will not succeed where mental incapacity is present.