Candler v Crane, Christmas & Co

E590298

Candler v Crane, Christmas & Co is a landmark English Court of Appeal case in which Lord Denning articulated the modern principle of liability for negligent misstatements in tort.

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Statements (40)

Predicate Object
instanceOf Court of Appeal of England and Wales case
English court case
areaOfLaw economic loss
negligence
negligent misstatement
tort law
category English Court of Appeal case
English tort case
citation [1951] 2 KB 164
country United Kingdom
court Court of Appeal of England and Wales NERFINISHED
decisionYear 1951
factSummary the claimant relied on negligently prepared accounts in making an investment
holding no duty of care was recognized on the facts by the majority
importance articulated the modern principle of liability for negligent misstatements in tort
influenceOn Hedley Byrne & Co Ltd v Heller & Partners Ltd NERFINISHED
judge Asquith LJ NERFINISHED
Cohen LJ NERFINISHED
Lord Denning NERFINISHED
jurisdiction England and Wales
keyConcept assumption of responsibility for statements
foreseeability of economic loss from reliance on statements
proximity between maker and recipient of statement
language English
leadingOpinionBy Lord Denning NERFINISHED
legalDoctrine negligent misrepresentation in tort
legalPrinciple duty of care in making statements causing pure economic loss
liability for negligent misstatements in tort
requirement of a special relationship for liability for negligent misstatement
legalStatus leading English authority on negligent misstatement prior to Hedley Byrne
party Candler NERFINISHED
Crane, Christmas & Co NERFINISHED
professionInvolved accountants
reporter King’s Bench reports NERFINISHED
result claim dismissed by the Court of Appeal majority
separateOpinion Lord Denning delivered a dissenting judgment NERFINISHED
subsequentDevelopment principles in Lord Denning’s dissent were later approved by the House of Lords in Hedley Byrne
timePeriod 20th century
topic professional negligence
pure economic loss

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Lord Denning notableWork Candler v Crane, Christmas & Co