Century Insurance Ltd v Northern Ireland Road Transport Board

Century Insurance Co Ltd v Northern Ireland Road Transport Board AC 509 is an English tort law case, concerning vicarious liability in English law.

Facts An delivery company employee, Davison, threw a lit match on a floor after lighting a cigarette at a petrol station, causing fire.D Nolan and K Oliphant, Lunney & Oliphant's Tort Law: Text and Materials (7th edn OUP 2023) ch 14, 862

Judgment The House of Lords held his conduct was in the course of employment.

Viscount Simon said it was negligence in the discharge of his duties.

Lord Wright held it was not prima facie negligent. Rather it was innocent. Only negligent through time and circumstance. You cannot treat the consequences as separate from the act. It did not matter that the acts were done for the driver’s own convenience rather than for the employer’s benefit.

See also

English tort law

References