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Gorris v. Scott

Citation. [1874] 9 L.R. (Exch.) 125
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Brief Fact Summary.

The Court of Exchequer ruled that a negligent claim can only be successful if the acts that are complained coincide with the purposes of the statute that the case is being brought under. 

Synopsis of Rule of Law.

A claim that is brought under a specific statute must be directly related to the meaning and reasoning behind the statute.

Facts.

Scott (Defendnat) was hired by Gorris (Plaintiff) to transport plaintiff’s sheep by boat. However, during a storm the sheep were all swept off of the boat by a large wave. Seeking to recover damages, Plaintiff relies on a statute known as the Contagious Diseases Act which states that any group of animals that are transported by boat must be separated and stored in a pen. The intent of the statute was to prevent disease. Plaintiff claims that if Defendant had followed the statute then his sheep would not have been lost. Plaintiff sues under a theory of negligence.

Issue.

Do a Defendant’s negligent acts have to relate directly to the statute’s purposes in order for the Plaintiff to recover damages. 

Held.

Yes. The statute in question was designed for public safety regarding sanitation. Therefore Plaintiff’s actions will not be successful because it was not directly related to the purpose of the statute.


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