Ratio Decidendi
Where the claimant suffers a subsequent injury from a different tortfeasor or event, the first tortfeasor remains liable for the original loss. The subsequent event does not reduce the first tortfeasor's liability.
Fapte
Baker injured his left leg in a road accident caused by Willoughby's negligence. Before the trial, Baker was shot in the same leg during an armed robbery and the leg was amputated. Willoughby argued his liability should be limited to the period before the shooting.
Rezumatul hotărârii
The House of Lords held that Willoughby remained liable for the full original disability. The shooting did not extinguish Baker's loss from the original accident — it merely added to it. To hold otherwise would leave Baker under-compensated, as neither tortfeasor would be fully liable.
Citate cheie
"A man is not compensated for the physical injury: he is compensated for the loss which he suffers as a result of that injury."
— Lord Reid
Tratament ulterior
Distinguished in Jobling v Associated Dairies [1982] where the subsequent event was a natural illness rather than a tortious act.