Donoghue v. Stevenson is a landmark legal case that established the modern concept of negligence in the field of tort law. The case was heard by the House of Lords, the highest appellate court in the United Kingdom, in 1932 and is often cited as a foundational case in the development of the law of negligence.
The case involved a woman named Mrs. Donoghue who consumed a bottle of ginger beer that was manufactured by a company called Stevenson. Inside the bottle, Mrs. Donoghue found the remains of a decomposed snail. As a result, she suffered shock and gastroenteritis. Mrs. Donoghue sued Stevenson, claiming that the presence of the snail in the ginger beer had caused her harm and that Stevenson was negligent in its manufacturing process.
The central issue in the case was whether Stevenson owed a duty of care to Mrs. Donoghue, and whether it had breached that duty. At the time, the law of negligence was largely based on the concept of privity of contract, which meant that a person could only sue for damages if they had a direct contractual relationship with the party responsible for the harm. However, Mrs. Donoghue had not purchased the ginger beer herself, but rather it was bought for her by a friend. Therefore, she did not have a contractual relationship with Stevenson.
The House of Lords, in a landmark decision, established the principle that a manufacturer owes a duty of care to the ultimate consumer of its product, even in the absence of a contractual relationship. This principle, known as the “neighbour principle,” was articulated by Lord Atkin, one of the judges in the case, who stated that “You must take reasonable care to avoid acts or omissions which you can reasonably foresee would be likely to injure your neighbour. Who, then, in law, is my neighbour? The answer seems to be – persons who are so closely and directly affected by my act that I ought reasonably to have them in contemplation as being so affected when I am directing my mind to the acts or omissions which are called in question.”
This landmark decision expanded the scope of liability for negligence and established the modern concept that individuals and companies owe a duty of care to others who may be affected by their actions or omissions, regardless of whether there is a contractual relationship. It has had a significant impact on the development of tort law and has been widely followed in other common law jurisdictions around the world.