R v Pittwood [1902] is a case that deals with the legal duty of care owed by a person who is employed to perform a specific function or task. The case was heard in the Queen’s Bench Division of the High Court of Justice in England.
R v Pittwood Case Facts
In this case, Mr. Pittwood was employed as a gatekeeper by the Great Western Railway Company. His job was to close the gate at a level crossing after a train had passed to prevent people from crossing the tracks until it was safe to do so. On one occasion, Mr. Pittwood failed to close the gate, and a horse-drawn carriage was hit by a train, resulting in the death of the driver. Mr. Pittwood was charged with manslaughter.
Legal issues
The legal issue in this case was whether Mr. Pittwood had a legal duty of care to close the gate and prevent people from crossing the tracks.
R v Pittwood Decision
The court held that Mr. Pittwood had a legal duty of care to close the gate and prevent people from crossing the tracks. His failure to do so amounted to a breach of that duty and was sufficient to establish the actus reus of manslaughter.
Reasoning
Legal duty of care
The court found that Mr. Pittwood had a legal duty of care to close the gate and prevent people from crossing the tracks. As a gatekeeper employed by the Great Western Railway Company, he had a specific function to perform, and his failure to perform that function resulted in the death of the carriage driver.
Breach of duty
The court also found that Mr. Pittwood’s failure to close the gate amounted to a breach of his duty of care. He had been trained and employed to perform a specific task, and his failure to do so was a clear breach of that duty.
Causation
The court also considered the issue of causation. It found that Mr. Pittwood’s failure to close the gate was a direct cause of the carriage driver’s death. If the gate had been closed, the carriage driver would not have been able to cross the tracks and would not have been hit by the train.
Legal significance
The decision in R v Pittwood [1902] has several legal significances, including:
- The principle of legal duty of care
The case established the principle that a person who is employed to perform a specific function or task owes a legal duty of care to perform that function or task. If the person fails to perform that function or task, he or she may be held liable for any resulting harm.
- The principle of breach of duty
The case also established the principle that a failure to perform a legal duty of care amounts to a breach of that duty. In other words, a person who fails to perform a specific function or task that he or she is employed to perform is in breach of his or her legal duty of care.
- The principle of causation
The case also established the principle that there must be a direct causal link between the breach of duty and the resulting harm. In other words, the breach of duty must be a direct cause of the harm suffered.
- The principle of strict liability
The case also raised the possibility of strict liability, which is a principle that holds a person liable for harm caused by his or her actions, regardless of fault. Although strict liability was not the basis of the decision in R v Pittwood [1902], it was raised as a possible argument.
Conclusion of R v Pittwood
R v Pittwood [1902] is an important case that established the principle of legal duty of care owed by a person who is employed to perform a specific function or task. The case also established the principle of breach of duty and the requirement for a direct causal link between the breach of duty and the