Divisional Court Cases
| Published date | 01 July 1955 |
| Date | 01 July 1955 |
| DOI | http://doi.org/10.1177/002201835501900304 |
| Subject Matter | Article |
Divisional Court Cases
DUTY TO REPORT ROAD ACCIDENTS
Quelch v. Phipps
THE general
purport
of s.
22
of
the
Road Traffic Act 1930
relating to
the
duty of a motorist to stop
and
supply
information or report to the Police when his vehicle has been
involved in a road accident, is well known,
but
the exact
scope of this section is by no means easy to define, as was
shown by the above-named case (1955 2
All
E.R. 302).
This
case arose out of an information heard by
the
justices for
the
City of Oxford which had been preferred
against
the
respondent, abus driver.
The
facts proved before
the
justices were that at about 7.30 p.m. on the 14th November
1954
the
respondent was driving amotor bus along High
Street, Oxford. As
the
bus approached the traffic lights at
the
junction of High Street
and
Longwall Street it slowed down
but, as
the
lights
turned
to green on the nearer approach of
the
bus,
the
vehicle did not stop until it reached a bus stop
on
the
far side of
the
road junction. As the bus was approaching
the
junction apassenger got off and in doing so fell and sustained
some injury.
It
was proved
that
the
conductor had warned
this passenger of
the
danger of what he was doing.
The
conductor left the bus
and
went to the passenger
and
took him
home
but
did
not
give the passenger any information as to
the
name of the driver or owner of the bus or of its number.
The
conductor reported the accident at Oxford City police station
at 9 a.m. on the 16th November.
The
driver first knew of
the
accident when the bus reached the bus stop.
He
made no
report of the accident to the Police.
The
relevant provisions of s.
22
of the Road Traffic Act
1930 are
that
by subsec.
(I):
"If
in any case owing to the presence of a motor
vehicle on a road an accident occurs whereby damage or
injury is caused to any person, vehicle or animal, the driver
of
the
motor vehicle shall stop and if required so to do by
222
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