Legal Watch:Personal Injury27th February 2015Issue: 053

Events

Plexus and Greenwoods hold a series of events which are open to interested clients. See below for those being held in the next few months:

The Major Bodily Injury Group (MBIG) | Spring Seminar | 28.04.15 | The Wellcome Collection, London

There is a limited number of seats still available for this event, so to avoid disappointment book your place now.

In this issue:

• Public liability

• RTA liability

• Damages

• Civil procedure/interim payment

• Costs/hourly rates

• Watch this space

Public liabilityReaderswillrecognisethefirstcasethisweekastheoneinwhich the Supreme Court had earlier set out the criteria which would give rise to the existence of a non-delegable duty of care. It found that the second defendant local education authority had owed a non-delegable duty of care to ensure thatreasonablecarewastakentosecurethesafetyofapupilwho was attending a swimming lesson conducted through an independent contractor.

The issue of liability has now been tried and is reported as Woodland (Protected Party) v Maxwell and Essex County Council (2015) EWHC 273 (QB).

The claimant had been injured while attending a school swimming lesson at a local authority pool. She was then 10 years old. Shortly after the claimant entered the water she was seenbytheswimmingteachertobefloatingvertically.Shedidnot respond to questioning or a physical touch. The teacher and another swimming teacher lifted her out of the water. She was assessed to be still breathing and was placed in the recovery position. Her breathing was seen to be erratic or fading. Mouth-to-mouth and cardio-pulmonary resuscitation wereadministered.Theclaimantwastakenbyambulancetohospital.Shehadsufferedcardiacarrestandaseriousbraininjurycausedthroughlackofoxygen.Sheclaimedagainstthelifeguard, who was on duty at the swimming pool at the material time, the swimming teacher and against the local authority on thebasisthatitowedanon-delegabledutytotakecareofherin school swimming lessons and that accordingly it would be liable for the negligence of the lifeguard and/or the swimming teacher. The claimant’s case was that the swimming teacher and/or the lifeguard had failed to exercise reasonable care in the performance of their duties on the day of the accident, in thateachfailedtokeeppupilsunderobservationwheninthewater and failed within a reasonable period of time to observe thattheclaimantwasindifficulties,raisethealarmandeffecta rescue. Her treatment after she had been removed from the water was not an issue at trial.

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Finding in favour of the claimant the High Court judge held that the claimant’s injuries were the consequence of a near-drowning episode, which would have started a minimum of30seconds fromthefirstsubmersionof theairways inwater, and the probability was that if she had been spotted andrescuedearlier,shewouldnothavesufferedtheinjurythat she did.

On the evidence, the claimant was in the water for at least 50secondsandwasindifficulty,takinginwaterforatleast30 seconds.

Thefactthattheclaimantwasindifficultywasnotnoticedbythe swimming teacher or the lifeguard. No good explanation was given as to why they failed to spot the claimant for as long as 20-30 seconds. The lifeguard had belatedly suggested that she was prevented from adequately performing her duties because the class had started early when she was not present. That was contrary to her earlier evidence and pleaded case and the late change of position was rejected.

The claimant’s fellow pupils had encountered her in the waterinanadvancedstateofdifficultiesandhadattemptedto rescue her. It followed that she had stopped swimming for longer than the minimum period of 30 seconds.

‘Both the lifeguard and the swimming teacher were negligent and the local authority was liable for their negligence.’Theswimmingteacher’sfailuretonoticeapupilindifficultiesin the water for more than 30 seconds fell below the standard of care reasonably to be expected of a teacher. It was not possibletodeterminewhyherattentionwasdeflectedfromthe pupils who were in the water and the one pupil who was indifficulty,butitwasdeflectedandtheopportunityforanearlier response was missed.

The lifeguard’s failure to observe the claimant was a failure to perform her role to the reasonable standard to be expected. Shewasnotpayingsufficientattentiontousersinthewaterat the material time.

Both the lifeguard and the swimming teacher were negligent and the local authority was liable for their negligence. The claimant succeeded on liability as their failures of the duty of care caused or materially contributed to the claimant’s injuries.

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RTA liabilityThe Scottish case of Jackson v Murray (2015) UKSC 5 is an interesting example of a court taking into accounta claimant’s age, in the context of her accident, when determining the appropriate discount for contributory negligence. After two appeals the Supreme Court has just provided its decision and settled the discount that should apply. The reduction for contributory negligence has been setat50%,significantlylowerthanthe90%reductionmadebythejudgeatfirstinstance.

The appellant/pursuer, who was then 13, had stepped out from behind her school minibus into the path of the respondent/defender’s car. The accident had occurred at around4.30pm,whenthelightwasfading.Atfirstinstance,the judge found that the respondent had failed to drive with reasonablecare.Heought tohavekept aproper lookoutandidentifiedthebusasbeingaschoolbus,oratleastabusfromwhichchildrenwerelikelytoalight;heoughtthentohaveforeseenthattherewasariskthatapersonmight,however foolishly, attempt to cross the road. The judge also found that he had failed to modify his driving: he did not reduce his speed from 50mph (the speed limit was 60mph) as he approached the bus; a reasonable speed in thecircumstances would have been between 30 and 40mph. However, the judge also found that the main cause of the accidentwas theappellant’s “recklessness” inattemptingtocrosstheroadwithouttakingpropercaretocheckthatitwasclear.Heassessedhercontributorynegligenceat90%.On appeal, the Inner House of the Court of Session reduced her contributory negligence to 70%.

Allowing the pursuer’s further appeal by a majority, the Supreme Court held that it was not possible for a court to arrive at an apportionment which was demonstrably correct. The apportionment of responsibility under S1(1) Law Reform (Contributory Negligence) Act 1945 was inevitably a somewhat rough and ready exercise. The test to be applied by an appellate court was whether the court below had gone wrong.

‘…a 13-year-old would not necessarily have the same level of judgment and self-control as an adult.’Intheabsenceofan identifiableerror,suchasanerroroflaw, or the taking into account of an irrelevantmatter, orthefailuretotakeaccountofarelevantmatter,itwasonlyadifferenceofviewastotheapportionmentofresponsibilitywhich exceeded the ambit of reasonable disagreement that would warrant a conclusion that the court below had gonewrong.TheInnerHouse(firstappealcourt)hadgonewrong. It had rightly considered that the appellant did not takereasonablecareforherownsafety:eithershedidnotlook to her left within a reasonable time before steppingoutorshefailedtomakeareasonablejudgmentastotheriskposedbytherespondent’scar.Ontheotherhand,asthe Inner House recognised, regard had to be had to the appellant’s circumstances. As the court pointed out, she was only 13 and a 13-year-old would not necessarily have the same level of judgment and self-control as an adult. As thecourtalsopointedout,shehadtotakeaccountoftherespondent’s car approaching at speed, in very poor light conditions, with its headlights on.

As the court recognised, the assessment of speed in those circumstances was far from easy, even for an adult. It was also necessary to bear in mind that the situation of a pedestrian attempting to cross a relatively major road with a60mphspeedlimit,afterduskandwithoutstreetlighting,was not straightforward, even for an adult. The Inner House considered that the respondent’s behaviour was “culpable to a substantial degree”. He had to observethe road ahead and keep a proper lookout, adjusting his

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speed in case a potential hazard presented itself. As the Inner House noted, he was found to have been driving at an excessive speed and not to havemodified his speedto take account of thepotential danger presentedby theminibus. The danger was obvious, because the minibus had its hazard lights on. Notwithstanding that danger, he continueddrivingat50mph.Asthe judgeatfirst instancehad noted, the Highway Code advised drivers that “at 40mphyourvehiclewillprobablykillanypedestriansithits”.That level of danger pointed to a very considerable degree of blameworthiness on the respondent’s part.

It was impossible to discern in the Inner House’s reasoning any satisfactory explanation of its conclusion that the major share of the responsibility should be attributed to the appellant. The respondent’s conduct played at least an equal part in causing the damage and was at least equally blameworthy. The proper assessment of contributory negligence was 50%.

CommentThis case illustrates that when considering contributory negligence in a case involving a child, age becomes particularly relevant when the circumstances are outside the norm. As the Supreme Court pointed out, the combination of factors in this casewouldhave causeddifficulty to anadult, let alone the average 13-year-old. The Inner House’s assessment of contributory negligence at 70% was rejected by reference to a number of authorities including that of Ehrari v Curry (2007), where contributory negligence was also assessed at 70%, but where the 13-year-old pedestrian steppeddirectly into thesidemirrorofa truckwhichwastravellingatareasonablespeed,andthedriverfailedtotakeavoiding action as promptly as he ought to have done.

For further information about this case please contact

Julie FisherPlexus Law (Scotland)T 0844 245 4804E:julie.fisher@plexuslaw.co.uk

A second case under this heading is Dursan v J Sainsbury Plc (2015) EWHC 233 (QB) which considered in detail the actions of an HGV driver involved in a fatal collision with a pedestrian.

Thedeceasedhadbeenknockedoverandkilledbyagoodsvehicle driven by an employee of the defendant company. The deceased had been crossing a two-lane road on foot, between lines of queuing traffic.He had started from thenearsidepavement,crossingtheinsidelaneoftrafficbehinda bus and continuing across the outside lane in front of the lorry. As he did so, the lorry moved forward and collided withhim.At the timeof theaccident itwasdark, thoughthe road was lit by vehicular, street and shop lighting. The deceased was wearing dark clothing; it was raining; thetraffic was stopping and starting; and pedestrians werecrossing the road in various places even though there was a pedestrian crossing a short distance away. The lorry was fittedwithmirrorswhichcompliedwithDirective 2003/97. They included a Class VI mirror on the nearside corner of the cab, giving a view of the blind spot immediately in front of the vehicle. It was common ground that once the deceased had begun to cross the road, the driver would only have been able to see him through his nearside mirrors, if at all. It was also common ground that there was no authoritative guidance as to the sequence in which visual checks shouldbemadeby thosedrivinggoods vehicles.The driver asserted that he had checked his nearsidewindow,hisnearsidemirrors,and thenhisoffsidemirrorsbefore moving forward, but had not seen the deceased. The jointexperts’evidencewasthatthosecheckswouldhavetakenhimbetweenthreeandsixseconds.

The claimant, the deceased’s widow, alleged that the driver shouldhavemadeafinalcheckinhisClassVImirrorbeforemoving forward.

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‘Since there was no prescribed or recommended sequence of visual checks, it was for the driver to do what he thought appropriate…’Dismissing the claim, the High Court judge held that the driver was conscientious and careful and had given truthful evidence. There was no doubt that he had carefully carried outthesequenceofvisualcheckshedescribed.Whiletherewas some attraction in the submission that he should have takenafinal look inhisClassVImirrorbeforepullingoff,the circumstances had to be considered. It was apparent from CCTV footage that the lorry had been positioned slightlyaheadof thebackof thebus,so therewassomeoverlap between the two vehicles. The deceased would thereforehavehadtonegotiateadog-legaroundthebackandoffsideofthebusbeforecrossinginfrontofthelorry.When thedriverbeganhissequenceofvisualchecks,hewould not have been able to see the deceased through his nearside window waiting to cross. Once the deceased began to cross, he would only have been visible through the nearside mirrors, and only for about half the time that he would have been visible had he not been obscured bythebackof thebus.Sincetherewasnoprescribedorrecommended sequence of visual checks, it was for thedriver to do what he thought appropriate, subject to the considerations described in the Highway Code and the handbook produced by the Driving Standards Agency.Thedrivercouldnotbecriticisedforcheckinghisnearsidewindow and mirrors, including his Class VI mirror, before checkinghisoffsideviews.Thequestionwaswhether,afterdoingso,heshouldhavere-checkedhisClassVImirror.Hisevidencewasthatthechecksrevealednothingtoalerthimto the possible presence of pedestrians in front of his lorry. Thatdidnotimplyanylackofcareonhispart.Evenifthe

relative positions of the bus and the lorry had allowed him a betterview,hemightwellhavefinishedhisnearsidechecksbefore the deceased came into view. Given the timings, it waslikelythathecheckedhisClassVImirroronlyasecondortwobeforepullingoff,anditwouldbeunreasonabletoexpect him to have anticipated a pedestrian entering that space during that time. The possibility that a pedestrian wouldcomedowntheoffsideofthebusandcrossthefrontof the lorry was not one that ought to have been within the driver’scontemplation.Moreover,evenifhehadre-checkedhis Class VI mirror, it could not be established that the deceased would have been visible. While the circumstances demandedasignificantdegreeofvigilancefromthedriver,therecouldbenojustifiablecriticismofhisnotre-checkinghis Class VI mirror before moving forward. The claimant hadthusfailedtoestablishanylackofreasonablecareonhis part. In failing to take precautions for his own safety,whether by using the pedestrian crossing, wearing lighter colouredclothing,ortakingalesshazardousrouteacrossthe road, the deceased had been the author of the accident.

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DamagesA hydrotherapy pool sometimes appears in a personal injury schedule of loss and raises a smile from the defending side. However, as the case of Ellison (Protected Party) v University Hospitals of Morecombe Bay NHS Foundation Trust (2015) EWHC 366 (QB) illustrates, the claim can be entirelyjustified.Thecasealsoinvolvedtheassessmentofa complex accommodation claim.

The claimant, who was born in 2007, suffered hypoxicischaemic injury at birth leading to severe quadrigplegic spastic cerebral palsy. She was totally immobile with virtually no spontaneous ability to use her hands and arms. She waseffectivelyblind,doublyincontinentanddependentontube feeding. Her cognitive and intellectual functions were immeasurablylow.Shealsosufferedfromfrequentpainfulspasms in her limbs, occurring day and night, which left her screaming and crying for prolonged periods. The only effectivewayofeasingthepaincausedbythespasmswasto immerse her in a hydrotherapy pool. The journey to and from the nearest pool was around two hours. The claimant’s life expectancy was almost 30 years. Her mother cared for her full time, assisted by grandparents. The claimant’s fatherwasanengineerwhohadworkedabroadinaseniorpositionwithafinalsalarypensionscheme,andthefamilyhad intended to move abroad until it became clear that the claimant’s condition made that impossible. The father gave up his job and provided consultancy services. However, due tothespecialistnatureofhisworkhewasforcedtoworkinLondonduringtheweekandtravelhometoCumbriaattheweekends,whichwasputtinganenormousstrainonthemarriage and on family life. The family therefore intended to move to London. The heads of damage in issue included general damages and the future costs of accommodation and hydrotherapy.

In assessing damages the High Court judge held that the claimant’s case included several features characteristic of the upper end of the Judicial College Guidelines for tetraplegia and very serious brain injury. Against that, it was

necessary to takeaccountof themitigating impactof thepain relief likely to be achieved by hydrotherapy and theclaimant’slackofinsightintohercondition.Theappropriatesumforgeneraldamageswas£295,000.

The stated intention of the family to move to London was genuineandwaslikelytobecarriedoutiftheclaimantwasgiven the means to bring that about. Although the move would result in a loss of the support provided by the family network, they would have paid professional carers. Thecommuting was unsustainable; themove to London wasrequired in order to maintain the cohesion of the marriage and the family unit.

When determining whether a given item of expenditure should be incurred to meet a claimant’s reasonable needs, it was relevant to consider whether the same or a substantially similar result could be achieved by other, less expensive, means. However, a general requirement of proportionality could not be applied to the quantification of damagesfor future costs, as that would be at odds with the basic rulesrelatingtocompensationfortort.Thecostofmakinggoodtheharmsufferedbytheclaimant,insofarasmoneycould do so, was not a defence if there were no cheaper alternativethatwouldproduceasubstantiallysimilareffect.The overwhelming evidence was that hydrotherapy was an effectivemeans of relieving the claimant’s pain and therewas no evidence that alternative measures provided a substantiallysimilareffect.Theavailabilityofpoolsoutsidethe home, even in London, did not correspond with the pattern or frequency of her symptoms of pain and screaming. Moreover, the nature, frequency and degree of pain involved meantthatthedifferencebetweentheeffectthatprovisionof in-home hydrotherapy would have, and the alternatives, made the cost proportionate to the need. Accordingly, in the exceptional circumstances of the case, a hydrotherapy pool in the home was reasonably required in order to provide the claimant with relief from the considerable and frequent pain thatshesufferedasaresultofherinjuries.

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‘The value of (uncompensated) losses comfortably exceeded the value to the parents of free accommodation in a home purchased with the claimant’s damages award.’Were it not for the claimant’s condition, the family would have enjoyed an expatriate lifestyle until the children reached secondary education age, at which time they would probably have either returned to the UK or moved to the US or Australia. They had incurred very considerable uncompensated loss,not least the lossof thefinal salarypension. The value of those losses comfortably exceeded the value to the parents of free accommodation in a home purchased with the claimant’s damages award. The sum reasonably required for a suitable house in London, of a size sufficient for the installation of a hydrotherapy pool, was£1.6m, plus £135,000 for the purposes of the calculation required by Roberts v Johnstone to represent the betterment that would be achieved by the adaptations required to meet the claimant’s needs.

The judge did not allow a claim for the installation of a lift to enabletheclaimanttoaccessthefirstfloorofthepropertythat would be bought. Nor did he allow the costs of the claimant travelling on holiday with her family after the age of 19.Heconsidereditunlikelythatshewoulddosoasinherconditionshewouldgainnodiscerniblebenefit.

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Civil procedure/interim paymentIt is some time since we have been able to report a case applying the test in Eeles v Cobham (2009) to an interim payment application made in respect of an accommodation claim. We now have one in MMM v Royal Berkshire NHS Foundation Trust [Lawtel 25/02/2015].

Theclaimantappliedforaninterimpaymentof£930,000inher personal injury claim against the defendant trust.

The defendant had admitted liability for the claimant’s injuries suffered at birth. She had sustained brain damage andsufferedfrommildcerebralpalsyasaresult,whichaffectedherbalance,motorskills,mobility,personalcareanddailyliving. Proceedings were issued in 2013 and an interim payment of £250,000 was made. There was uncertainty as to the claimant’s prognosis and so the proceedings were stayed until 2016. The claimant, who was eight years old, lived with her family in split-level accommodation. Medical evidence from 2013 suggested that although she could climbthestairssherisked injurydoingsobecauseofherimpairedmobilityandthatshewasmorelikelytofall.Moreup-to-date medical evidence stated that her ability to climb the stairs was limited by fatigue and that she was unable to carry things while climbing the stairs because of her impaired motorskills. Ifsheneededtogoupstairsherparentshadto carry her and when she did her physiotherapy it would be done in the front room so everyone had to vacate that area. A total sum of £1.6m was being claimed and an interim paymentof£93,000forsuitableaccommodationwhichwasallononeleveland10hoursofcommercialcareperweek.

Allowing the application the deputy High Court judge held that the claimant’s claim in respect of care was conservative. Around-the-clock care had not been sought. Ten hours aweekwastheminimumthatwouldberequired.Itwaslikelythat more hours might be required if the claimant fell ill or if her family were unable to assist as they had been.

Theclaimantsought£80,000forpain,sufferingandlossofamenity, which was, in the circumstances, a conservative

amount. The court had been referred to the relevant guidelines, including those for neck injuries where therehad been a loss of function of the limbs and the guidelines formoderatebraindamage.Thebracket forneck injurieswas £55,000 to £100,000 and the bracket for moderatebrain damage was £80,000 to £126,000. It was clear that the claimant was not claiming an excessive amount. Indeed in another reported case the victim, who suffered similarinjuries to the claimant, was awarded £160,000 for PSLA.

‘It was likely that the claimant would succeed in the final action in getting accommodation…’The claimant’s existing accommodation was unsuitable. There was insufficient storage space for her soon-to-bearriving second wheelchair; insufficient space for her todo her physiotherapy; and she had difficulty accessingand using the bathroom and toilet facilities and climbing the stairs. The risk of the claimant falling while climbingthe stairs, given the medical evidence, justified a moveto accommodation all on one level. As she grew it would become increasingly difficult for her parents to carry herupstairs, and there was no reason for them to have to do that. Itwas likely that the claimantwould succeed in thefinal action in getting accommodation, but shemight notsucceed in getting all of the adaptations to the property sought. Accordingly, the sum for adaptations was to be discounted.Takingintoaccounttheinterimpaymentalreadymade,the£930,000nowclaimedconstitutedareasonableproportion of the overall damages and would be awarded.

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Costs/hourly ratesThe case of Kelly v Hays Plc and another [Lawtel 23/02/2015] looks at the age old problem of the cost of a claimantinstructingaLondonfirmofsolicitorswhenshecouldhaveinstructed a firm elsewhere which would have chargedlower fees.

The respondent/claimant, whom the appellant/defendants had employed in outer London, had commenced a personal injury claim against them, on the basis that she had been injured through their failure to provide her with a safeplacetowork.Theclaimwasforover£433,000.Thedefendants said that they had surveillance evidence that showed that she had not suffered any personal injury orhad exaggerated the claim, and that the claim was statute barred. In November 2013, the defendants agreed to pay theclaimant£50,000infullandfinalsettlementoftheclaim,plus the costs of the action, to be assessed if not agreed. The parties did not reach agreement. A hearing was set to determine a preliminary costs issue, namely in determining costs, what the claimant’s solicitors’ hourly rates should be. ShehadinstructedaCityofLondonfirm,withratesrangingfrom between £160 and £450 per hour. The defendants argued that that was unreasonable and that the hourly rates ofanationalbandonefirm,whichwerebetween£118and£217, were appropriate. The Master stated that the test was whether it was objectively reasonable for the claimant to instructaCityfirm.Hesaid that the issue thathehad todeterminewaswhich firm it would have been objectivelyreasonable to have instructed. He noted that the respondent was not required to have approached the cheapest solicitor and found that it would have been objectively reasonable forhertohaveinstructedacentralLondonfirm.Heupliftedtheratesby20%totakeaccountofthefactthatitwasamulti-trackcaseandthattherewascomplexityovercertainissues, so that the hourly fee rates ranged between £140 and £380.

The defendant appealed and submitted that it was wrong to say that it was appropriate to instruct a central London firm;theMasterhadaskedthewrongquestionandfailedtoprovide reasons.

Allowing the appeal the High Court judge held that the appeal was by way of review rather than rehearing. Accordingly, it could only be allowed where the decision was plainly wrong, there had been a defect in reasoning, the Masterhadfailedtotakeintoaccountarelevantmatterorhadtakenintoaccountanirrelevantmatter,ortherewasaserious procedural irregularity. There could be no criticism of the Master’s observation that the appellant had not been required to approach the cheapest firm.He did not havetomakeabinarychoicebetweenanationalbandonefirmoraCityfirm.TheMasterhadawidediscretion.However,he had not only failed to provide reasons as to why central London hourly rates were preferable, he had also failed to provide reasons for rejecting the defendants’ submissions that a national bandone firmwas appropriate. The courtwasnotsatisfied thathehadasked thecorrectquestion,namelywhattypeoffirmshouldhavebeenretained.

‘No part of the claim had raised issues which needed experts over and above the expertise of a normal experienced solicitor.’Even if the correct question had been posed, the conclusion was not one which it was reasonable for him to have reached on the material before him. It was thus appropriate for the instant court to reach its own determination on thematter, taking into accountCPR 44.4(3). The relevant

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factors were: the importance of the matter, any legal complexities, the location of the claimant’s home and her placeofwork,andwhatsheknewaboutthefees.Althoughsome aspects of the claim had been complex, it was a relatively straightforward personal injury claim. No part of the claim had raised issues which needed experts over and above the expertise of a normal experienced solicitor. The claimant’shomewasjustoutsideLondonandsheworkedin outer London. The appropriate category of solicitors was national band one. However, there had been some aspects of complexity, which would justify some enhancement to the hourly rates. Those aspects were the limitation point, the extent of damages and the consideration of surveillance evidence.Althoughsomedegreeofupliftshouldbetaken,thatwaslesslikelytoapplyfurtherdownthepeckingorderof fee grades. It was reasonable to select fee earners of £295forgradeA,£230forgradeB,£175forgradeCand£120 for grade D.

The information and opinions contained in this document are not intended to be a comprehensive study, nor to provide legal advice, and should not be relied on or treated as a substitute for specific advice concerning individual situations. This document speaks as of its date and does not reflect any changes in law or practice after that date. Plexus Law and Greenwoods Solicitors are trading names of Parabis Law LLP, a Limited Liability Partnership incorporated in England & Wales. Reg No: OC315763. Registered office: 12 Dingwall Road, Croydon, CR0 2NA. Parabis Law LLP is authorised and regulated by the SRA.

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