Ratio Decidendi
A sports governing body that assumes responsibility for the medical safety of participants owes them a duty of care. If the body's rules require medical provision, it must ensure that provision is adequate.
Facts
Michael Watson, a professional boxer, suffered severe brain injuries during a title fight. He claimed the British Boxing Board of Control was negligent in failing to ensure adequate ringside medical facilities. Had proper resuscitation been available, his injuries would have been less severe.
Judgment Summary
The Court of Appeal held that the BBBC owed a duty of care to boxers to ensure adequate medical arrangements. The BBBC had assumed responsibility for medical safety through its rules and regulations. The failure to require immediate ringside resuscitation constituted a breach of that duty.
Key Quotes
"The Board had complete control over the medical facilities at the fight. The boxers were entitled to rely on the Board to ensure that those facilities were adequate."
— Lord Phillips MR
Subsequent Treatment
Led to fundamental reforms in boxing medical safety standards worldwide.
Extended to other sports regarding governing body duties for participant safety.