Facts
- Mrs. Sayers became trapped inside a public lavatory cubicle owned and operated by Harlow Urban District Council due to a malfunctioning door lock.
- After unsuccessfully seeking help for fifteen minutes, she attempted to climb over the door to escape.
- She placed one foot on the toilet seat, the other on the toilet roll holder, and held onto the door and a pipe.
- The toilet roll holder rotated when she placed her weight on it, causing her to fall and injure herself.
- Mrs. Sayers sued the local authority, alleging that their failure to maintain the lock constituted negligence resulting in her harm.
Issues
- Whether Harlow Urban District Council was negligent in failing to maintain the lavatory door lock.
- Whether the injury sustained by Mrs. Sayers was a foreseeable and not too remote consequence of the council’s negligence.
- Whether Mrs. Sayers’ actions amounted to contributory negligence, justifying a reduction in damages.
Decision
- The Court of Appeal found the council negligent for failing to maintain the lavatory lock.
- The injury suffered by Mrs. Sayers was determined to be a foreseeable result of the council's negligence and not too remote.
- The court held that Mrs. Sayers bore partial responsibility, as she should have realized the toilet roll holder was not suitable to bear her weight.
- Damages awarded to Mrs. Sayers were reduced by 25 percent to reflect her contributory negligence.
Legal Principles
- Liability for negligence requires a breach of duty of care resulting in foreseeable harm.
- The doctrine of remoteness limits liability to damage that is a natural and probable consequence of the negligent act.
- Claimant responses to negligent acts are not too remote if they are reasonable and foreseeable under the circumstances.
- Contributory negligence applies where the claimant’s actions contribute in part to the harm, reducing the recoverable damages proportionally.
Conclusion
The Court of Appeal allowed Mrs. Sayers' appeal, finding the local authority liable for negligence but reducing her damages by 25% due to contributory negligence, and clarified the application of remoteness and claimant response in negligence cases.