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.
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 ⓘ |
Referenced by (1)
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