Adams v Lancashire & Yorkshire Rail – Case Summary

Adams v Lancashire & Yorkshire Railway Company

Court of Common Pleas

Citations: (1868-69) LR 4 CP 739.


The claimant was a passenger on a train owned by the defendant. During the train journey, the train door flew open on four occasions. This was because of the defendant’s negligence. It was possible for the claimant to conveniently avoid danger by sitting further inside the carriage. Instead, the claimant closed the door four times. On the fourth occasion, the claimant fell out of the train and was injured.

  1. Did the defendant’s negligence cause the claimant’s injury?

The Court held in favour of the defendant. The negligence had not caused the claimant’s injury.

This Case is Authority For…

If the claimant is injured because he acted in a way which was highly unreasonable due to the danger and the availability of other convenient options, the defendant shall not be taken to have caused the injury.


Smith J stated, obiter, that if the defendant’s negligence puts the claimant in a position where he is in danger if he acts and in danger if he does nothing, then any injury suffered as a result of the claimant’s attempts to escape the danger will normally be attributed to the defendant. The same is true if the claimant would be put to great inconvenience if he did not act and the risk of acting was very small.

While this case is most directly relevant to causation, it might also provide guidance on how modern courts approach the issue of contributory negligence (which did not exist in the same form at the time).