Tort; Negligence; causation of harm; the extent of harm caused; plaintiff's individual frailty; 'eggshell skull' rule.
Facts: Stephenson suffered a cut to his hand because of his employer's negligent conduct. This initial injury was of a kind that was reasonably foreseeable. However, Stephenson was an unusually vulnerable person, and complications following the cut resulted in him becoming very ill indeed, both physically, and psychologically.
Issue: Was the defendant liable when the extent of the harm was due to the plaintiff's special susceptibility to the complications that followed the initial injury?
Decision: The defendant was liable for all of the harm suffered by the plaintiff, even the harm that was suffered because of the plaintiff’s special susceptibility to complications.
Reason: Richmond J held that the 'eggshell skull' rule remains the law despite the decision in Overseas Tankship (UK) Ltd v Morts Dock & Engineering Co Ltd (The Wagon Mound (No 1)) [1961] AC 388. This means that questions of foreseeability are limited to the initial injury, after which a defendant will be liable for any further damage resulting from any pre-existing special susceptibility of the plaintiff.