Corr v IBC Vehicles Ltd
House of Lords
Citations:  UKHL 13;  1 AC 884;  2 WLR 499;  2 All ER 943;  ICR 372;  PIQR P11.
The claimant’s husband was an engineer who suffered a workplace injury. The injury left him disfigured and caused him to suffer post-traumatic stress disorder and worsening depression. As a result, he committed suicide. The claimant sued under the Fatal Accidents Act 1976. The defendant, the man’s employer, accepted liability in negligence for the man’s initial injuries and the consequent psychiatric harm. However, they argued that any losses resulting from the man’s death should not be recoverable.
- Was suicide outside of the scope of the duty of care owed by the defendant to their employees?
- Was the suicide a novus actus interveniens which broke causation?
- Did the suicide trigger the defence of volenti non fit injuria?
- Did the suicide amount to contributory negligence?
The House of Lords held in favour of the widow. The defendant was liable for the man’s death in addition to his initial injuries, subject to an appropriate deduction for contributory negligence.
This Case is Authority For…
Where the defendant owes a duty not to cause psychiatric harm, and the claimant commits suicide because of the defendant’s actions, this falls within the scope of the defendant’s duty. It does not matter that the claimant was not legally insane: it was enough that the defendant’s acts rendered them not fully responsible.
Causation & Remoteness
Suicide can only be a novus actus interveniens if done consciously and voluntarily in the absence of mental illness. Where it results from a reduction in capacity caused by the defendant’s breach, it will not break causation.
Where psychiatric harm such as depression is a foreseeable result of the breach, there is no need to demonstrate that suicide specifically was foreseeable to establish that the loss was not too remote.
Deliberate self-harm, even when influence by mental illness, can constitute contributory negligence.
The court held that defence of volenti non fit injuria was irrelevant because the defendant obviously did not consent to his initial injury. The judges concluded that deceased did not consent to suicide either, because of the diminished capacity caused by his mental illness.