Donoghue V Stevenson - Significance

Significance

The case was reviewed by Frederick Pollock in a 1933 edition of Law Quarterly Review, in which he commented that there was no doubt as to the importance of the decision and that "a notable step has been made in enlarging and clarifying our conception of a citizen's duty before the law ... not to turn dangerous or noxious things loose on the world". However, Donoghue otherwise attracted little attention; it was understood only as precedent that manufacturers were liable for injuries their goods cause their ultimate consumers rather than that there was a general principle of liability in negligence. The majority of the Court of Appeal (Lord Justice Cohen and Lord Justice Asquith) therefore held in Candler v Crane, Christmas & Co that Donoghue had not affected tortious liability for negligent misstatement. This narrow understanding of Donoghue changed with the cases of Hedley Byrne v Heller in 1963 and Home Office v Dorset Yacht Co in 1970.