Lamb v Camden London Borough Council [1981] QB 625 (QB)

Facts

The defendant council was responsible for maintaining street lighting. A streetlight was left unrepaired, creating a dark area. A third party, taking advantage of the darkness, attacked the claimant, causing injury.

The claimant argued that the council’s negligence in failing to repair the light caused his injuries.

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Issue

Does a third-party criminal act break the chain of causation, relieving a defendant of liability?

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Decision

The court held that the council was not liable. The criminal act of a third party was unforeseeable and independent. The council could not reasonably have anticipated that someone would use the darkness to commit the attack.

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Legal Principle

A novus actus interveniens (new intervening act) can break the chain of causation if it is independent and unforeseeable. Foreseeable third-party acts generally do not break the chain.

Liability only extends to harm that is a reasonably foreseeable consequence of the defendant’s breach.

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Importance

• Key authority on intervening acts in negligence.

• Helps distinguish between direct causation and consequences interrupted by independent acts.

• Important in public liability and local authority negligence cases.