Paris v Stepney Borough Council [1951] AC 367 (HL)

Facts

Mr Paris was employed by the defendant council as a garage hand. He had sight in only one eye, a fact known to his employer. While working underneath a vehicle, a piece of metal flew into his good eye, causing total blindness.

At the time, it was not common practice to provide protective goggles for this type of work. The employer argued that the risk of eye injury was small and that they had complied with general workplace standards.

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Issue

Does the standard of care increase where the defendant knows that the claimant has a particular vulnerability?

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Decision

The House of Lords held that the employer was negligent. Although the general risk of eye injury was small, the consequences for this particular employee were extremely serious because he had only one functioning eye. The employer should have taken additional precautions.

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Legal Principle

The magnitude of risk includes not just the likelihood of harm, but the seriousness of potential injury. Where a defendant knows of a claimant’s special vulnerability, greater precautions may be required.

Breach is assessed by balancing likelihood of harm against seriousness of consequences.

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Importance

• Key authority on how courts assess risk magnitude in breach cases. Shows that the reasonable person must take into account known vulnerabilities.

• Often contrasted with Bolton v Stone (low probability cases).

• Important in workplace and medical negligence contexts.