Facts
- Mr. Tarleton, a lorry driver employed by Weetabix, was unknowingly suffering from a malignant insulinoma causing hypoglycemia, which impaired his brain function and ability to drive.
- While driving, he entered a hypoglycemic state that diminished his capacity, leading to a crash into the claimant's property.
- Mr. Tarleton was not fully unconscious but was unaware of his impairment at the time of the accident.
- Medical evidence confirmed that had he realized his condition, he would have stopped driving to avoid causing harm.
- The legal question arose whether the standard of care for a driver should account for an unknown medical condition.
Issues
- Whether the standard of care in negligence should be modified for a defendant whose capacity is unknowingly impaired by a medical condition.
- Whether Mr. Tarleton could be held liable for breach of duty given his lack of awareness of his impairment at the time of the accident.
- Whether strict liability should apply in cases of harm caused by individuals suffering from undiscovered medical impairments.
Decision
- The Court of Appeal determined that the standard of care required was that of a reasonably competent driver who is unaware of any impairment affecting his ability to drive.
- The court concluded that Mr. Tarleton had not breached his duty of care, as he could not have reasonably known about his condition.
- The appeal was allowed, and Mr. Tarleton (Weetabix) was not held liable for the damage caused.
- The court rejected the imposition of strict liability in these circumstances.
Legal Principles
- The standard of care in negligence is generally objective, but can be modified if the defendant suffers from an unknown medical impairment.
- Individuals should not be required to guard against risks arising from conditions they could not reasonably have known about.
- The ruling distinguished between negligence and strict liability, clarifying that liability in tort should reflect the defendant’s knowledge and circumstances.
- The judgment does not excuse all impairments, only those of which the defendant was genuinely unaware.
- The case contrasts with later authority, particularly Dunnage v Randall, which rejected consideration of certain types of impairment.
Conclusion
The Court of Appeal in Mansfield v Weetabix Ltd established that a defendant is to be judged against the standard of a reasonably competent person unaware of their impairment, thereby introducing a necessary modification to the objective standard of care in negligence where undiagnosed medical conditions are involved and rejecting strict liability in such cases.