Analysis

DOI10.3366/E1364980909000717
AuthorElizabeth Shaw,Findlay Stark,William M Gordon,Peter Webster,Ross Gilbert Anderson,Lesley-Anne Barnes,David Cabrelli,Iain Jamieson,Douglas Brodie,Lindsay Farmer,Robert Goddard
Date01 September 2009
Pages477-533
Published date01 September 2009

The primary hurdle for the pursuers was that their claim was in respect of an omission, not commission: the Council, it was argued, should have acted so as to protect Mitchell from Drummond. Sometimes the distinction between act and omission can be difficult to draw.6

Lord Rodger (at para 55) and Baroness Hale (at para 76) noted that this case was not a “pure” omission as the Council were actors in the events which led to Mitchell's death: they had arranged the meeting with Drummond and so had “provided the opportunity” for the attack. However, the pursuers’ argument was still that the Council had failed to take steps to protect Mitchell from a third party and so the rules on omissions were still applicable.

Critically, it is not simply a distinction between activity and passivity.7

C McIvor, Third Party Liability in Tort (2006) 9.

However, “despite the difficulties, the distinction is fundamentally sound”.8

Stovin v Wise[1996] AC 923 at 930B per Lord Nicholls. For statements of the principle, see, e.g., Dorset Yacht Co Ltd v Home Office[1970] AC 1004 at 1060 per Lord Diplock; Stovin v Wise at 929H-931D per Lord Nicholls, 943E-944G per Lord Hoffmann.

It is, in the words of Cardozo CJ, the difference between being an “instrument of harm” and an “instrument of good”.9

HR Moch Co Inc v Rensselaer Water Co 159 NE 896 (1928) at 898.

To distinguish
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