"Donoghue v Stevenson (1932)" is one of the most influential cases in the history of English and Scottish law and is fundamental in the law of negligence, laying the groundwork for the modern concept of a duty of care. Here's a detailed summary:
- Date: 1932
- Parties: May Donoghue (Plaintiff) vs. David Stevenson (Defendant)
- Context: The case arose from an incident in a café in Paisley, Scotland.
- Incident: May Donoghue consumed a ginger beer purchased for her by a friend. The ginger beer was in an opaque bottle, and after consuming some of it, she discovered the remains of a decomposed snail in the bottle.
- Illness: Donoghue later suffered from gastroenteritis and shock, allegedly due to the snail.
- Lawsuit: Since Donoghue did not buy the ginger beer herself, she did not have a contract with the café owner or Stevenson, the manufacturer. Therefore, she sued Stevenson in tort.
- Claim: Donoghue claimed that Stevenson owed her a duty of care, which he breached by allowing the drink to become contaminated.
- Key Legal Question: Whether a manufacturer owes a duty of care to the ultimate consumer of a product.
- Decision: The House of Lords held in favor of Donoghue.
- Reasoning: Lord Atkin introduced the "neighbour principle," stating that one must take reasonable care to avoid acts or omissions reasonably foreseeable to cause harm to one's "neighbors" - those closely and directly affected by one's acts.
- Outcome: The case established the principle that Stevenson, and by extension all manufacturers, owed a duty of care to consumers, which could be breached resulting in liability for negligence.
Legacy and Importance
- Impact on Tort Law: "Donoghue v Stevenson" is often cited as the foundational case for the modern law of negligence, particularly in the area of product liability.
- Wider Influence: The case significantly influenced the development of the common law world’s tort law, specifically in the area of negligence and duty of care.
- Educational Significance: The case is a staple in legal education, widely taught in law schools across common law jurisdictions.
The case of "Donoghue v Stevenson" marked a pivotal shift in legal thinking about the duty of care and negligence, fundamentally shaping the law of tort and consumer protection.