Paris v Stepney Borough Council [1951] AC 367 (HL)

Facts

  • The claimant was employed in a garage owned by the defendant borough council.
  • The claimant, known to his employer, had only one good eye, making him especially vulnerable to injury.
  • While at work, a metal fragment struck the claimant’s good eye, leaving him blind.
  • The defendant did not provide goggles to any employees, including the claimant.
  • At the time, the defendant’s practice of not supplying goggles was in line with general employer standards.
  • The claimant brought a negligence action, alleging breach of the common law duty of care for failing to protect him from foreseeable harm due to his known vulnerability.

Issues

  1. Whether the standard of care in negligence should be adjusted to take into account the claimant's known special vulnerability.
  2. Whether the employer's failure to provide goggles to the claimant constituted a breach of duty, notwithstanding compliance with general practices.
  3. Whether the consequences of potential harm to an individual employee should shape the reasonable steps required from an employer.

Decision

  • The House of Lords allowed the claimant’s appeal, overturning the Court of Appeal’s decision.
  • The Court held that the defendant employer had breached its duty of care by failing to provide protective equipment given the claimant's known vulnerability.
  • Their Lordships reasoned that awareness of a particular risk to an employee imposes a heightened duty to take reasonable precautions.
  • The standard of care, while generally objective, must reflect the specific circumstances and consequences for the claimant.

Legal Principles

  • The standard of care in negligence is not absolute but must be tailored to the individual circumstances of the claimant, especially if particular vulnerabilities are known to the defendant.
  • Foreseeable risks and their potential seriousness must influence what a reasonable person or employer would have done.
  • Defendants must balance operational burdens with obligations to safeguard against avoidable harm to especially vulnerable individuals.
  • Compliance with general standards does not absolve a defendant of the obligation to consider special risks to particular claimants.

Conclusion

The decision in Paris v Stepney Borough Council established that the reasonable standard of care in negligence law requires special consideration of a claimant's known vulnerabilities, mandating greater precautions where the foreseeability and severity of harm are heightened.

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