Donoghue v. Stevenson
Donoghue v. Stevenson (1932)
Court: House of Lords, United Kingdom
Area of Law: Tort Law – Negligence
Facts of the Case
May Donoghue was given a bottle of ginger beer bought by her friend from a café in Paisley, Scotland.
The bottle was opaque, and after drinking some, she discovered a decomposed snail in it.
She suffered gastroenteritis and severe shock as a result.
Donoghue sued the manufacturer, David Stevenson, for negligence, claiming he owed her a duty of care.
Legal Issue
Whether a manufacturer owes a duty of care to a consumer who did not purchase the product directly (no contract existed between Donoghue and Stevenson).
Could she hold the manufacturer liable for harm caused by negligence?
Judgment
Lord Atkin delivered the leading judgment.
He established the “Neighbor Principle”:
“You must take reasonable care to avoid acts or omissions which you can reasonably foresee would be likely to injure your neighbor. Who, then, is my neighbor? Persons who are so closely and directly affected by my act that I ought reasonably to have them in contemplation.”
The court held that the manufacturer owed a duty of care to the ultimate consumer.
Stevenson was liable because he failed to ensure the product was safe for consumption.
Key Principles Established
Duty of Care: A person must take reasonable care to avoid causing foreseeable harm to others.
Negligence: Breach of this duty resulting in harm can lead to liability.
Proximity: Liability arises not only from contractual relationships but also from foreseeable harm to persons closely affected by one’s actions.
Consumer Protection: The case laid the foundation for modern product liability law.
Significance
Donoghue v. Stevenson is considered the birth of modern negligence law.
It shifted tort law from a strict contractual approach to one based on duty of care and foreseeability.
The neighbor principle has influenced negligence law worldwide, including India, especially in consumer protection and tort cases.
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