Spartan Steel & Alloys Ltd v Martin & Co (Contractors) Ltd
E590300
Spartan Steel & Alloys Ltd v Martin & Co (Contractors) Ltd is a leading English Court of Appeal case on negligence and pure economic loss, noted for Lord Denning’s influential judgment limiting recovery for relational economic loss.
All labels observed (1)
| Label | Occurrences |
|---|---|
| Spartan Steel & Alloys Ltd v Martin & Co (Contractors) Ltd canonical | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T6384692 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: Spartan Steel & Alloys Ltd v Martin & Co (Contractors) Ltd Context triple: [Lord Denning, notableWork, Spartan Steel & Alloys Ltd v Martin & Co (Contractors) Ltd]
-
A.
Allied Structural Steel Co. v. Spannaus
Allied Structural Steel Co. v. Spannaus is a 1978 U.S. Supreme Court case that limited state interference with private contracts by striking down a Minnesota pension law as violating the Constitution’s Contract Clause.
-
B.
Sibbach v. Wilson & Co.
Sibbach v. Wilson & Co. is a 1941 U.S. Supreme Court case that upheld the validity of the Federal Rules of Civil Procedure under the Rules Enabling Act and helped define the scope of federal procedural rulemaking.
-
C.
Stack v. Boyle
Stack v. Boyle is a 1951 U.S. Supreme Court case that established constitutional limits on excessive bail in the context of prosecutions under the Smith Act.
-
D.
Steward Machine Co. v. Davis
Steward Machine Co. v. Davis is a 1937 U.S. Supreme Court case that upheld the federal unemployment compensation provisions of the Social Security Act, affirming broad congressional power to tax and spend for the general welfare.
-
E.
Somerset v Stewart
Somerset v Stewart was a landmark 1772 English court case that effectively declared slavery unsupported by English common law, becoming a pivotal moment in the British abolitionist movement.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: Spartan Steel & Alloys Ltd v Martin & Co (Contractors) Ltd Target entity description: Spartan Steel & Alloys Ltd v Martin & Co (Contractors) Ltd is a leading English Court of Appeal case on negligence and pure economic loss, noted for Lord Denning’s influential judgment limiting recovery for relational economic loss.
-
A.
Allied Structural Steel Co. v. Spannaus
Allied Structural Steel Co. v. Spannaus is a 1978 U.S. Supreme Court case that limited state interference with private contracts by striking down a Minnesota pension law as violating the Constitution’s Contract Clause.
-
B.
Sibbach v. Wilson & Co.
Sibbach v. Wilson & Co. is a 1941 U.S. Supreme Court case that upheld the validity of the Federal Rules of Civil Procedure under the Rules Enabling Act and helped define the scope of federal procedural rulemaking.
-
C.
Stack v. Boyle
Stack v. Boyle is a 1951 U.S. Supreme Court case that established constitutional limits on excessive bail in the context of prosecutions under the Smith Act.
-
D.
Steward Machine Co. v. Davis
Steward Machine Co. v. Davis is a 1937 U.S. Supreme Court case that upheld the federal unemployment compensation provisions of the Social Security Act, affirming broad congressional power to tax and spend for the general welfare.
-
E.
Somerset v Stewart
Somerset v Stewart was a landmark 1772 English court case that effectively declared slavery unsupported by English common law, becoming a pivotal moment in the British abolitionist movement.
- F. None of above. chosen
Statements (47)
| Predicate | Object |
|---|---|
| instanceOf |
Court of Appeal of England and Wales decision
ⓘ
English court case ⓘ |
| areaOfLaw |
economic loss
ⓘ
negligence ⓘ tort law ⓘ |
| categoryOfLossNotRecoverable |
pure economic loss unconnected to physical damage
ⓘ
relational economic loss from interruption of a power supply ⓘ |
| categoryOfLossRecoverable |
consequential economic loss linked to physical damage
ⓘ
physical damage to property ⓘ |
| citation |
[1972] 3 All ER 557
ⓘ
[1972] 3 WLR 502 ⓘ [1973] QB 27 ⓘ |
| country | England and Wales NERFINISHED ⓘ |
| court | Court of Appeal of England and Wales NERFINISHED ⓘ |
| decisionOnDamages |
damages awarded for physical damage to the melt and profit on that melt
ⓘ
damages refused for loss of profits on melts that would have been processed during the period of power failure ⓘ |
| factSummary |
claimant also claimed for loss of profits on further melts that could not be processed during the outage
ⓘ
defendant contractors negligently damaged an electricity cable supplying power to claimant’s steel factory ⓘ power cut caused damage to a melt in claimant’s furnace and loss of profit on that melt ⓘ |
| holding | claimant could recover for physical damage to property and consequential loss but not for pure economic loss from lost future profits ⓘ |
| judge |
Edmund Davies LJ
NERFINISHED
ⓘ
Lawton LJ NERFINISHED ⓘ Lord Denning MR NERFINISHED ⓘ |
| jurisdiction | England and Wales ⓘ |
| languageOfDecision | English ⓘ |
| lawReportSeries | Queen’s Bench Reports NERFINISHED ⓘ |
| leadingJudge | Lord Denning MR NERFINISHED ⓘ |
| legalIssue |
duty of care for economic loss caused by damage to property of a third party
ⓘ
recovery for pure economic loss in negligence ⓘ |
| legalPrinciple |
distinction between consequential economic loss and pure economic loss
ⓘ
limitation on recovery for relational economic loss ⓘ policy-based restriction on indeterminate liability for economic loss ⓘ pure economic loss is generally not recoverable in negligence absent special circumstances ⓘ |
| LordDenningView | imposing liability for all economic loss from power cuts would expose defendants to liability in an indeterminate amount for an indeterminate time to an indeterminate class ⓘ |
| opinionBy | Lord Denning MR NERFINISHED ⓘ |
| parties |
Martin & Co (Contractors) Ltd
NERFINISHED
ⓘ
Spartan Steel & Alloys Ltd NERFINISHED ⓘ |
| proceduralPosture | appeal to the Court of Appeal ⓘ |
| relatedConcept |
consequential loss
ⓘ
duty of care in negligence ⓘ pure economic loss ⓘ relational economic loss ⓘ |
| significance |
frequently cited in subsequent cases on economic loss and duty of care
ⓘ
illustrates policy-based reasoning in tort law ⓘ leading authority on limits of recovery for pure economic loss in English negligence law ⓘ |
| subjectMatter | damage caused by negligent interference with electricity supply to a factory ⓘ |
| yearDecided | 1972 ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: Spartan Steel & Alloys Ltd v Martin & Co (Contractors) Ltd Description of subject: Spartan Steel & Alloys Ltd v Martin & Co (Contractors) Ltd is a leading English Court of Appeal case on negligence and pure economic loss, noted for Lord Denning’s influential judgment limiting recovery for relational economic loss.
Referenced by (1)
Full triples — surface form annotated when it differs from this entity's canonical label.