ARCHITECTS, BREACH OF DUTY AND CAUSATION

J D Williams & Co Ltd v Michael Hyde & Associates Ltd [2001] BLR 99

In J D Williams & Co Ltd v Michael Hyde & Associates Ltd [2001] BLR 99 the Court of Appeal considered, once again, the scope of the decision in Bolam v Friern Hospital Management Committee [1957] 1 WLR 582 and concluded, albeit for different reasons, that it is not a rule of universal application in professional negligence claims. On the facts of the case the trial judge was held to have been entitled to conclude that the defendants had been negligent but he was held to have erred in finding that the defendants’ negligence had caused loss to the claimants. The evidence before the judge did not entitle him to conclude that there was a sufficient causal connection between the defendants’ negligence and the loss to the claimants. The defendants’ appeal was therefore allowed.