Corr v IBC Vehicles Ltd

Corr v IBC Vehicles Ltd
Court	House of Lords
Citation	[2008] UKHL 13, [2008] AC 884

Corr v IBC Vehicles Ltd [2008] UKHL 13 is an English tort law case, ^[1] concerning causation between a breach of duty and damage.

Facts

Deceased killed himself after becoming depressed following a bad accident that IBC Vehicles was responsible for.

Judgment

The House of Lords rejected that suicide was a novus actus interveniens that prevented the widow claiming loss of deependency under the Fatal Accidents Act 1976. ^[2]

Lord Bingham, rational of the novus actus principle was it is not fair to hold a defendant liable for damage caused by someone else. An example of a new cause was ‘a voluntary, informed decision taken by the victim as an adult of sound mind.’ But the suicide was not a voluntary, informed decision of this kind. It was a response of a man suffering severe mental illness, impairing his capacity.

Lord Neuberger [65] asked whether deceased had ‘no real “fault” ... for his suicide.’ Majority held suicide did justify reduction in damages for contributory negligence. He retained some capacity.

See also

• English tort law

References

1. Corr v IBC Vehicles Ltd [2008] UKHL 13 , [2008] 1 AC 884, [2008] AC 884, [2008] 2 WLR 499, [2008] 2 All ER 943, [2008] ICR 372, [2008] PIQR P11(27 February 2008)
2. D Nolan and K Oliphant, Lunney & Oliphant's Tort Law: Text and Materials (7th edn 2023) ch 5, 280