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How far a tortfeasor can be held responsible for his actions or omissions in causing an injury was the issue exercising the House of Lords in Corr v IBC Vehicles Ltd (2008) UKHL 13, [2008] All ER (D) 386 (Feb).
The facts were straightforward. Thomas Corr had suffered a serious accident at work. The defendants had admitted liability. As a result of the accident and ensuing physical injuries, he had developed a severe depressive illness which responded poorly to treatment and got worse. One day, in despair, he jumped from the top of a multi-storey car park and killed himself. His widow claimed damages for the physical and psychiatric injuries he had suffered. While the principles applicable to her claim were clear enough, the claim for recovery of financial loss due to her husband’s suicide was in issue.
The defendants asserted that his suicide was outside their duty of care, that it was too remote, that it could not have been reasonably foreseen and that the fatal act had broken the chain of causation. In other words, the defence was
