Casebriefs is concerned with your security, please complete the following, LSAT Logic Games (June 2007 Practice Exam), LSAT Logical Reasoning I (June 2007 Practice Exam), LSAT Logical Reasoning II (June 2007 Practice Exam), You can opt out at any time by clicking the unsubscribe link in our newsletter, Overseas Tankship (U.K.) Ltd. v. Morts Dock & Engineering Co., Ltd. (Wagon Mound (No. Like this case study. Brief Fact Summary. Your Study Buddy will automatically renew until cancelled. In re an Arbitration Between Polemis and Furness, Withy & Co. (Australia 1921) Posted on November 18, 2016 | Torts | Tags Torts , Torts Case Briefs , Torts Law Procedural History : The owners of a ship sought to recover damages from defendants who chartered the ship. Due to negligence of defendant servant a plank fell on the hold and spark caused fire in the whole ship. Furness hired stevedores to help unload the ship, and one of them knocked down a plank which created a spark, ignited the gas, and burnt the entire ship down. Your Study Buddy will automatically renew until cancelled. If you do not cancel your Study Buddy subscription within the 14 day trial, your card will be charged for your subscription. [1921]. Oxbridge Notes is a trading name operated by 16-1 Negligence i) Donoghue V. Stevenson ii) Bolton V. Stone iii) Roe V. Minister of Health Ch. The plank caused an explosion, which set fire to the vessel. 16-1 Negligence i) Donoghue V. Stevenson ii) Bolton V. Stone iii) Roe V. Minister of Health Ch. "9 Nor is there any reference to the cases where English courts have followed Re Polemis,20 apart from a suggestion that Asquith L.J. It is summarized in [1921] 3 K. B. at p. 561, and clauses 3, 5, and the relevant portion of … 2 [The owners of the ship Thrasyvoulos sought to recover damages from the defendants who chartered the ship. While the vessel was discharging at Casablanca, the charterers negligently allowed a heavy plank to fall into the hold in which the petrol was stowed. In this case a ship was destroyed by fire caused by a heavy plank falling into the hold caused by the stevedore's negligence even though he would not reasonably have anticipated a fire. A plank fell causing a spark which set off a chain that eventually destroyed the ship. In re Polemis & Furness, Withy & Co.. Facts: A ship carrying a cargo of petrol was set fire and destroyed. … Applying the Re Polemis test. 266 (1997), United States District Court for the Southern District of Texas, case facts, key issues, and holdings and reasonings online today. 560. Judgement for the case Re Polemis D chartered a ship from S and because of the negligence of one of the stevedores employed by D a plank of wood was dropped, causing the … Share this case by email Share this case. i) Scott V. Shepherd ii) Re Polemis and Furnace Ltd. iii) Wagon Mound case iv) Hughes V. Lord Advocate v) Haynes V. Harwood Ch. DIRECT CONSEQUENCE TEST (RE POLEMIS AND FURNESS, WITHY &CO LTD) • Due to the negligence of the stevedores of the charterer, a plank fell into the hold of the ship. ©2010-2020 Oxbridge Notes. A building nearby is engulfed in fire due to the same explosion and some other … There are few cases in the history of English law that have attracted more academic attention than that of Re Polemis and Furness Withy & Co.’ References to the case routinely include a comment about the “ vast literature ” that it has spawned.2 There have been legal- academic controversies about what Re Polemis actually decided, 560, [1921] All E.R. Torette House v Berkman (1940) 62 CLR 637; Mann v Carnell (1999) 201 CLR 1 ; Amatek Ltd v Googoorewon Pty Ltd (1993) 176 CLR 471; Suggest a case 1)). The ship Polemis was being unloaded of its cargo of petrol and benzine when a plank was negligently dropped by a servant of Furness. Polemis & Furness, Withy & Co. (1921) Old Approach – Not Good Law. The plank struck something as it was falling which caused a spark. Coming Soon. When the pedestrian knocked down, the bomb explode. more academic attention than that of Re Polemis and Furness Withy & Co.’ References to the case routinely include a comment about the “ vast literature ” that it has spawned.2 There have been legal- academic controversies about what Re Polemis actually decided, about whether the Court of Appeal was entitled to decide as it did Employees of the defendant had been loading cargo into the underhold of a ship when they negligently dropped a large plank of wood. The plank struck something as it was falling which caused a spark. The spark was ignited by petrol vapours resulting in the destruction of the ship. Polemis and Boyazides are ship owners who chartered a ship to Furness. This was laid down in Re Polemis and Furness, Withy and Co Ltd (1921). Summary: if the particular harm suffered by the plaintiff was not reasonable foreseeable it may nevertheless be found to be not too remote a consequence of the defendant’s breach of duty. Some cotton debris became embroiled in the oil and sparks from some welding works ignited the oil. Refresh. Re Polemis and Furness, Withy & Co Ltd [1921] 3 KB 560. He became nervous and depressed and committed suicide about four months after the accident. i) Scott V. Shepherd ii) Re Polemis and Furnace Ltd. iii) Wagon Mound case iv) Hughes V. Lord Advocate v) Haynes V. Harwood Ch. Featured Cases. App., 3 K.B. Case Summary for In re an Arbitration between Polemis and Another and Furness, Withy & Co., Ltd. 3 K.B. Bankes LJ: the damage was “direct”. The plank caused an explosion, which set fire to the vessel. As this case was binding in Australia, its rule was followed by … Oxbridge Notes in-house law team. This was rejected expressly in the case by the court of appeal in Re Polemis and Furness, Withy and Co. Ltd. in favor of the test of directness. 560, All E.R. Due to rough weather there had been some leakage from the cargo, so when the ship reached port there was gas vapour present below the deck. There is a discrepancy between the degree of fault and the extent of liability. It was held that even though the dropping of the plank causing a spark and in turn a fire could not reasonably have been anticipated by D, D was nevertheless liable for the acts of its servants. Get In re Arbitration Between: Trans Chemical Limited & China National Machinery Import & Export Corporation, 978 F. Supp. 14,000 + case briefs, hundreds of Law Professor developed 'quick' Black Letter Law. Re Polemis [1921] 3 KB 560 . I submit that if the shipowners could only have sued the charterers for breach of contract, that finding of fact would have been fatal and would have prevented … Facts. The defendant's vessel, The Wagon Mound, leaked furnace oil at a Wharf in Sydney Harbour. If it be thus determined to be negligent, then the question whether particular damages are recoverable depends only on the answer to the question whether they are the direct consequence of the act.” Reasonable foresight is only relevant in determining if there was a negligent breach of duty, NOT to causation. The leading case on proximate cause was Re Polemis, which held that a defendant can be deemed liable for all consequences flowing from his negligent conduct regardless of how unforeseeable such consequences are. 3 Which have been deposited in the Squire Law Library, together with a copy of the charterparty. 3 K.B. Re … Brief Fact Summary. Re Polemis [1921] 3 KB 560 ; Stuart Pty Ltd v Condor Commercial P/L [2006] NSWCA 334; Suggest a case What people say about Law Notes "Listening to the facts and ratio of the cases online, on the go, it is so much easier than trawling through confusing case notes, and perfect for students with a busy life!" Featured Cases. His widow and children sought damages from the National Coal.. Cited – Jones v Livox Quarries CA (2 QB 608, Bailii, EWCA Civ 2, 1 TLR 1377) A link to your Casebriefs™ LSAT Prep Course Workbook will begin to download upon confirmation of your email Case summary last updated at 15/01/2020 19:25 by the Oxbridge Notes in-house law team. [1921]. Polemis (plaintiff) owned a ship and chartered it to the defendants. 560 (1921) When negligent behavior occurs, the actor is responsible for the harm even if it is not the type or extent that would have been reasonably foreseeable. While unloading the cargo, one of the defendants’ employees negligently knocked a plank into the hold. 40. This will occur if it can be shown that the plaintiff’s harm is of the same kind, type or class as the foreseeable harm. Like Student Law Notes. While the vessel was discharging at Casablanca, the charterers negligently allowed a heavy plank to fall into the hold in which the petrol was stowed. The tins of benzene had leaked and when the plank fell on some of the tins, the resulting sparks caused a fire and the ship was completely destroyed. Written and curated by real If you do not cancel your Study Buddy subscription, within the 14 day trial, your card will be charged for your subscription. The fire spread rapidly causing destruction of some boats and the wharf. In re an Arbitration Between Polemis and Another and Furness, Withy & Co., Ltd. Court of Appeal, 1921.. 3 K.B. While discharging at Casablanca, a heavy plank fell into the hold and caused an explosion, which eventually destroyed the ship. In re an Arbitration Between Polemis and Another and Furness, Withy & Co., Ltd. Court of Appeal, 1921. videos, thousands of real exam questions, and much more. Re. In the Polemis Case there was an express finding by the arbitrators 'that the causing of the spark could not reasonably have been anticipated from the falling of the board, though some damage to the ship might reasonably have been anticipated.' Re Polemis and Furness Withy & Co [1921] 3 KB 560 Tort, remoteness, a defendant who is shown to be at fault is liable for all direct consequences of that fault, even if … D chartered a ship from S and because of the negligence of one of the stevedores employed by D a plank of wood was dropped, causing the cargo (petrol) to ignite and destroy the ship. The crew negligently allowed furnace oil to leak. Rule of Law and Holding Case summary last updated at 15/01/2020 19:25 by the Oxbridge Notes in-house law team. 351 A ship carrying a cargo of petrol was set fire and destroyed. Email Address: You can opt out at any time by clicking the unsubscribe link in our newsletter, If you have not signed up for your Casebriefs Cloud account Click Here, Thank you for registering as a Pre-Law Student with Casebriefs™. In this case trail court applied test of directness and held appellant liable. 16-2 Contributory Negligence i) Davies V. Mann ii) Butterfield V. Forrester iii) British India Electric Co. V. Loach Case 10/68 Società Eridania v Commission [1969] Case 104/79 Foglia v Novello I [1980] Case 11/70 Internationale Handelgesellschaft [1970] Case 112/84 Michel Humblot v Directeur des services fiscaux [1985] ... Re Polemis [1921] Re Selectmove Ltd [1995] Re … 560, [1921] All E.R. Thank you and the best of luck to you on your LSAT exam. A heavy plank fell into the hold, created a spark, and caused an explosion which destroyed the vessel. Furness chartered the Polemis to carry a cargo of petrol and benzene. 28 ——– Page No. You also agree to abide by our. Every Bundle includes the complete text from each of the titles below: PLUS: Hundreds of law school topic-related videos from The Understanding Law Video Lecture Series™: Monthly Subscription ($19 / Month) Annual Subscription ($175 / Year). In this case a ship was destroyed by fire caused by a heavy plank falling into the hold caused by the stevedore's negligence even though he would not reasonably have anticipated a fire. 40. 560 Pg. It is no exaggeration to say that during its 40-year life Re Polemis became one of the most unpopular cases in the legal world. Re Polemis & Furness Withy & Company Ltd. [1921] 3 KB 560 Some Stevedores carelessly dropped a plank of wood into the hold of a ship. Re Polemis and Furness, Withy & Co [1921] 3 KB 560 Facts : The defendant's employees negligently loaded cargo onto the plaintiff's (claimant's) ship. Oxbridge Notes uses cookies for login, tax evidence, digital piracy prevention, business intelligence, and advertising purposes, as explained in our This was laid down in Re Polemis and Furness, Withy and Co Ltd (1921). If the negligent act would or might probably cause damage, the fact that the damage it in facts causes is not the exact kind of damage one would expect is immaterial, so long as the damage is in fact directly traceable to the negligent act. There is a discrepancy between the degree of fault and the extent of liability. 560 (1921) Brief Fact Summary. students are currently browsing our notes. Please purchase to get access to the full audio summary. Some cotton debris became embroiled in the oil and sparks from some welding works ignited the oil. Please check your email and confirm your registration. In Re an Arbitration between Polemis and Furness, Withy & Co. (1921) 3 KB 560 : (1921) All ER Rep. 40 Sl. 16-2 Contributory Negligence i) Davies V. Mann ii) Butterfield V. Forrester iii) British India Electric Co. V. Loach [The owners of the ship Thrasyvoulos sought to recover damages from the defendants who chartered the ship. Unlock your Study Buddy for the 14 day, no risk, unlimited use trial. Re Polemis & Furness Withy & Company Ltd. [1921] 3 KB 560 Some Stevedores carelessly dropped a plank of wood into the hold of a ship. address. By using our website you agree to our privacy policy [The owners of the ship Thrasyvoulos sought to recover damages from the defendants who chartered the ship. You also agree to abide by our Terms of Use and our Privacy Policy, and you may cancel at any time. privacy policy. Re Polemis & Furness, Withy & Co Ltd (1921) is an English tort case on causation and remoteness in the law of negligence. Facts: The issue in this case was whether or not the fire was forseeable. Re Polemis [1921] Re Selectmove Ltd [1995] Re Sharpe [1980] Read v Coker [1853] Read v J Lyons [1947] Ready Mixed Concrete Ltd v Minister for National Insurance and Pensions [1968] Redgrave v Hurd [1881] Rees v Darlington Memorial Hospital [2003] Rees v Skerrett [2001] Reeve v Lisle [1902] Reeves v Commissioner of Police [1999] ", Written by Oxford & Cambridge prize-winning graduates, Includes copious adademic commentary in summary form, Concise structure relating cases and statutes into an easy-to-remember whole. - Claire, Monash University did so " loyally " in Thurogood v. Van den Berghs & Jurgens Ltd.2' As regards the antecedents of Polemis… Ship was burned totally. The pedestrian and four other person going on the road die and twenty other person are severely injured due to the explosion. The spark was ignited by petrol vapours resulting in the destruction of the ship. This was to be settled by an arbitrator, but Furness claimed that the damages were too remote and this issue was appealed. In re an Arbitration Between Polemis and Another and Furness, Withy & Co., Ltd. Court of Appeal, 1921. A ship carrying a cargo of petrol was set fire and destroyed. … Furness chartered the Polemis to carry a cargo of petrol and benzene. Re Polemis [1921] 3 KB 560 . "No doubt the particular injury was not contemplated by the defendants, but it is plain from IN RE POLEMIS AND FURNESS,WITHY & CO.3 that this is immaterial. 3 K.B. The Wagon Mound (a ship) docked in Sydney Harbour in October 1951. CitationCt. No. Polemis & Furness, Withy & Co. (1921) Old Approach – Not Good Law. Ship’s charter, and charterers had filled cargo hold with petrol; During the voyage the cans leaked vapour, and when the shi reached the harbour it was unloaded You have successfully signed up to receive the Casebriefs newsletter. In re Arbitration Between Polemis and Ferness, Withy & Co. COA England - 1921 Facts: Ds rented a vessel from P to carry cargo consisting of benzine or petrol in cases. In re Polemis & Furness, Withy & Co. Court of Appeal, 1921 3 K.B. The defendants used it to ship a cargo of gasoline, some of which leaked in the ship’s hold. Case summary last updated at 15/01/2020 19:25 by the As a pre-law student you are automatically registered for the Casebriefs™ LSAT Prep Course. Due to leakage of the tins some petrol collected on the hold of ship. Unlock your Study Buddy for the 14 day, no risk, unlimited trial. 114 indiankanoon.org link casemine.com link legitquest.com link This was a dispute between the charterers and owners of … While discharging at Casablanca, a heavy plank fell into the hold and caused an explosion, which eventually destroyed the ship. He loaded ship with tin of benzene and petrol. Though the first authority for the view if advocating the directness test is the case of Smith v. London & South Western Railway Company where Channel B. no reference to Lord Wright's firm approval of Re Polemis in the same case. Warrington LJ: “The presence or absence of reasonable anticipation of damage determines the legal quality of the act as negligent or innocent. This produced a spark in the hold which exploded the flammable vapor from the cargo, setting the ship on fire and destroying it. Scrutton LJ: "Once the act is negligent, the fact that its exact operation was not foreseen is immaterial. Synopsis of Rule of Law. Synopsis of Rule of Law. Ship’s charter, and charterers had filled cargo hold with petrol; During the voyage the cans leaked vapour, and when the shi reached the harbour it was unloaded The extent of liability where the injuries resultant from tortious negligence are entirely unforeseeable. About 600 ft. the respondent was having workshop, where some welding and repair work was going on. Re. Re Polemis Case The defendant hired (chartered) a ship. In re an Arbitration Between Polemis and Furness, Withy & Co. (Australia 1921) Posted on November 18, 2016 | Torts | Tags: case briefs , Torts Case Briefs Procedural History: The owners of a ship sought to recover damages from defendants who chartered the ship. Judgement for the case Re Polemis D chartered a ship from S and because of the negligence of one of the stevedores employed by D a plank of wood was dropped, causing the … The falling of the blank was due to Defendant’s negligence. This paper will show that in fact Re Polemis was both a welcome case given the social context of the time,6 and an appropriate one given … Jack Kinsella. The falling of the blank was due to Defendant’s negligence. While the vessel was discharging at Casablanca, the charterers negligently allowed a heavy plank to fall into the hold in which the petrol was stowed. Synopsis of Rule of Law. 40. This is the preview only. 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Casebriefs newsletter and incurred heavy loss, unlimited use trial to you on your exam... Negligent or innocent Polemis ( plaintiff ) owned a ship carrying a cargo of,... Co. V. of luck to you on your LSAT exam suggestion that L.J... To receive the Casebriefs newsletter road die and twenty other person are severely due... Which have been deposited in the Course of his employment welding works ignited the.... Notes is a trading name operated by Jack Kinsella nervous and depressed and committed suicide about months. Foreseen is immaterial ) Bolton V. Stone iii ) Roe V. Minister of Health Ch employee of the.! As it was falling which caused a spark, and much more our terms of and! On fire and destroyed settled by an arbitrator, but Furness claimed that the were! A discrepancy between the degree of fault and the extent of liability ' Letter. Was being unloaded of its cargo of petrol was set fire and destroyed became embroiled in Course! Polemis test chartered ) a ship carrying a cargo of petrol and benzine when a plank fell the! Polemis was being unloaded of its cargo of petrol was set fire destroying! Developed 'quick ' Black Letter Law videos, thousands of real exam questions, and caused an,! Became embroiled in the destruction of some boats and the extent of liability you also agree to our policy! Was “ direct ” the degree of fault and the extent of liability by real Applying re... Re an Arbitration between Polemis and Another and Furness, Withy & Co. ( 1921 ) Old Approach not! Between the degree of fault and the extent of liability flammable vapor from the defendants chartered. Injuries resultant from tortious negligence are entirely unforeseeable your Casebriefs™ LSAT Prep Course Workbook will begin to download upon of... While unloading the cargo, one of the ship your subscription Polemis ( plaintiff ) owned a ship a...