John Macdonell.

The law of master and servant. Part I.--Common law. Part II.-- Statute law online

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Edirard>^ \. London and North-
JFesfern. lixj. Co. (May, 1870), L.
E. 5 C. P. 445 ; 39 L. .J. C. P.
241 ; -l-l L. T. 656 ; 18 W. E.
834. (See p. 287.)

JJ'alker v. South EosteDi Ih/. Co.
(1870), L. E. 5 C. P. 640 : 39 L.
J. C. P. 346; 23 L. T. 14; 18
W. E. 1032. (See p. 287.)

Allen V. London and (Treat
JFestcni L'lf. Co. (1870), L. E. 6
Q. B. 65 ; 40 L. J. Q. B. 55 ; 23 L.
T. 612; 19 W. K. 127. (See
p. 287.)

Foreman v. Mai/or of Canterbnrii
(1871), L. E. 6 Q. B. 214. (De-
fendants liable for negligence of




])roperly left to tlu' jury to say
Avlii'tlier driver was acting Avitliiu
scope of liis einploymeiit, and that
tliey were jiistitied in tinding that
lie was.)

Van Den Enynde v. Ulster Uy.
Co. (1871), 5 Ir. C. L. 6 and
.328. (A clerk of the defendants,
while issuing tickets, erroneously
thought he had seen a ticket in
tlie plaintilf's hand ; charged him
with having stolen a ticket ; and
detained him ; defendants liable.)

Moore v. Metropolitan liif. Co.
(1872), L. E. 8 Q. B. 36 ; 42 L. J.
q. B. 23 ; 27 L. T. 579 ; 21 W. R.
145. (See p. 288.)

Bay ley v. Man ch ester a nd Stafth'd-
.shire liii. Co-. (1872), L. K. 7'C. P.
415 ; 41 L. J. C. P. 278. (Plaintiff
took his seat in defendants' train
i'or Macclesfield ; a porter of tlie
defendants, supposing he was in
the wrong train, violently pulled
him out and injured him.)

JFard v. (leneral Oimnhus Co.
(1873), 42 L. J. C. P. 265 ; 28 L.
T. 850 ; affirmed, 27 L. T. 761 ;
21 W. K. 358. (Blow struck by
driver of defendants' omnibus at
<1 river of another omnibus ; pas-
senger in former injured ; Court
lefused to set aside verdict for
j)laintitf on the ground that there
■w as evidence of negligence in the
course of employment.)

Burns v. Poulsom (1873), L. R.
8 C. P. 563 ; 42 L. J. C. P. 302 ;
29 L. T. 329: 22 W. R. 20. (De-
fendant, a stevedore, employed to
.sliip lails, had a foi'eman, whose
duty it was to carry the rails to the
.ship after the .carman liad brought
tlieni to the (piay, and ludoaded
them. Tlie foreman voluntarily
got into the cait, and negligently
unloaded some lails whereby the
jilaintilf was injured. Evidence
lor a jury that foreman was acting-
w ithin scojie of his duty so as to
make stevedore liable. Brett, J.,

Tehbutlv.Bristolliy. C'o.(1870), L.

No Liability.
servants employed in repairing

Cormieh v. Diijhij (1876), i) Irish
C. L. 557. (Defendant's Steward
and herd got leave to go to a
neighbouring town, on business of
his own, with his master's
and cart ; it was afterwards agreed
that he should l)ring home meat
for the defendant ; he drove the
cart so negligently as to injure the
plaintiff ; Court refused to hold,
as matter of law, defendant liable.

liaynerx. Mitchell (1817), L.R. 2
C. P. D. 357. (Defendant's carman,
without his master's jiermission,
took horse and cart out of his
master's stable to deliver a child's
coffin at a relative's house ; he
picked up two or three barrels at
public-houses which defendant
su])plied. He drove against
Ijlaintiffs cart, and inj ured it.

Bank of New South Jl'cdes v.
Oicston (1879), L. R. 4 Ap. 270.
(Action for malicious prosecution
against a bank ; prosecution insti-
tuted by bank manager ; no im-
2)lied authority from his position to
institute prosecutions.)

Bolinqhroole v. Local Board,
Swindon (l):il4), L. R. 9 C. P. 575 ;
43 L. .1. C. P. 575; 3 L. T. 723;
23 W. R. 47. (See p. 282.)

Stercns v. Woodicnrd (1881),
L. R. 6 Q. B. D. 318. (See p. 286.)

master's liability to third ti^rsons.



]l. 6 Q. B. 73 ; 40 L. .1. Q. B. 78 ;
23 L. T. 772 ; 1!) W. K. 383. (The
stiitionsofdeleiulantsiiiul two (ithcr
luilwiiy conipiiuies were adjoining,
and the passenger.- of the dillerent
companies passed from one to the
other, the y\-\u>\(' area being used
in common. Tlie phiintilf, while
on the phitform (if the (k'fendants
on his way from the terminus of

1 me of the (companies to the Ijooking
oihce of another, >\as injurecl by
the negligence of a i>orter of the
defendants. Defendants liable, al-
liiough plaintiff not a passenger of
the (lefendants.)

Mackay v. Commercial Bank of
New Brunswick (1874), L. R. 5 P.
C. 394. (Cashier of a bank who
acted as manager, fraudulently
induced plaintilf to accept certain
bills ; the defendants obtained the
• benefit of the bills.)

Venables v. Smith (1877), L. R.

2 Q. B. D. 279 ; 46 L. J. Q. B. 470 ;
36 L. T. 509 ; 2o W. R. 384. (Cab-
owner liable for negligence of
driver who, on his return to owner's
mews, drove a little way from them
to purchase snuff for liimself.)

Edwards v. Midland liij. Co.
(1880), L. R. 6 Q. B. D. 287. (Ac-
tion for malicious prosecution lies
against a company. )

Scotch Cases.

Limoood v. Hathorn, (1817), 19 F.
C. 327 ; I. S. App. 20. (The ser-
vants of defendant cut down a tree
close to a public road ; it fell upon
and killed a man ; the defendant
not liable, — he being at the time
absent, and having given no
authority to cut the tree, nor
apparently any authority to cut
trees in that locality.)

Bairdx. Graham {It^rvZ), 14 D. 61").
(A master sent his servant with
glandered horse to a fair at such a
distance that th e servant was obliged
to put up for the night ; action by
owner of stable for loss of horses

No Liability.

Scotch Cases.
Waldie v. Duke of Boxburfjh
(1822), 1 S. 367. (R. obtained
an interdict against W. from deepen-
ing part of the river Tweed ; W.'s
servant, in his masters absence,
and against his'^press orders, com-
mitted a breach of the interdict ;
W. not responsible.)




No Liability

Scotch Casks.
and cattle which dereiidaiit's
had infected with glandeis.)

Faukh V. ToH-Hsend (1801), 23 D.
437 ; 33 ,lur. 224. (A manufactur-
ing chemist, whose business con-
sisted partly in hoiling down the
carcases of horses for manure, liable
in the full value of a .stolen horse/
which had l)een purchased liy his
servant and used for the above
purpose. )

Gregunj x. Hill (1869), 8 U. 282.
(Defendant employed foreman and
masons to build a house, and paid
them wages ; he also entered int(i
a contract with a carpenter for
carpenter's work ; held that the
detendant was liable for injuries
to carpenter l)y the negligence of
the masons.)

AiiEiiicAN Cases.

Philadelplda and Reading liy.
Co. V. Uerhij (1852), 14 How. 468.
(Defendants liable for collision
caused Ijy servants disobeying an
express order.)

Carman v. Mayor of Neiu York
(1862), 14 Abb. 301. (Owner of
land employed workmen to cut
trees on his own hind without
employing a competent superin-
tendent, or instructing them as to
the boundaries ; defendant liable
for trees of plaintiif which his
workmen ignorantly cut down and

Althorf v. JFolf (1860), 8 8m.
,355. (8ee page 272.)

Chapman v. X^ York Cndrul
Ji'y. Co. (1865). (Defendants liable
for torts of servants when drunk.)

Lannoi v. A Ihany Cas Liijlit Co.
(1871), 44 N. Y. 459. (Defendants,
informed that gas was escaping in
the cellar of a house, sent servant
to ascertain where the leak was ;
the servant lighted a match for
this purpose, and an explo.sion
took place ; defendants liable.)

H'ulfey. Ahnwi ean {IH^)'.)), 4 Duer

American Casios.

Wright V. Wilcox (1838), 19
Wend. 343. (Master not liable
when a servant wilfully threw a lail
off a waygonand drove over him.)

MaliY. Lord (1868). 39 N. Y.
381. (Defendant not liable for
the act of his superintendent in
arresting and searching the
plaintiff, on a charge of stealing
goods from the defendant.)

Frascr v. Frecmnn (1871), 43 N.
Y. 566. Defendant, under claim
of right, endeavoured to force his
way, with the aiil of his servant,
into premises of plaintilf's intes-
tate ; servant shot the latter in
the struggle ; defendant not liabh-,
in the ab-sence of evidence tliat
sliot was fired Avith assent or by
direction of defendant.)

master's liability to THIIU) PERSONS.



Ajierican Casks.
473. (No defencu tluit defendant's
servant, wilfully drove a.^^ainst
plaintitrs wa.^gon, if he did soin
order to avoid greater peril, which
it was the defendant's interest to

Railroad Co. v. Hanning (1872),
19 Wal. G49. (Contractor agreed
to furnish the materials and labour
for building a wharf ; to do the
work under the direction and
supervision of the railway com-
pany's engineer and to his satis-
faction ; the comijany liable for
the negligence of the contractor or
his servants.)

No Liability.

master's liability to servants.

A MASTER is not liable at Common Law to his servants
for the acts of fellow servants in the course of their

This has been altered by the Employers' LiabiHty Act of
1880, which is printed in the second part of this volume.
But as the Common Law is still partly in force, it will be
advisable to state what it was before the passing of that Act.
The reasons assigned for the exemption above stated are very
various. Sometimes it is put on the ground of general policy,
and on the inexpediency of exposing a master to a multipli-
city of actions (a). Sometimes the reason assigned is that a
servant does, as an implied part of the contract between
himself and his master, take upon himself the natural risks
and perils incident to the performance of his services (h) ;
or it is said that the liability of the master for the acts of the
servant is an exception which ought not to be extended, and
that the servant has no cause of action against his fellow
servant because, " he has not stipulated for a right of action
against his master if he sustains damage from the negligence
of a fellow servant " (c). Perhaps the most generally accepted
reason is that stated by Shaw, J., in Farwcll v. Bodov
Railroad Co. (d). " The implied contract of the master does

(a) PrlrsHrijv. Fonicr(lS^7),^'M. ('•) liramwcll, B., in Sirninson v.

& W. 1. f/tc Kiirth-Eadcrn liij. Go. (1878),

(h) Morqan v. Yah of Neath Ji>i. \.. R. 3 Kx. D. 341 ;' 47 L. J. E.x.

Co., 33 L.' J. Q. B. 260 ; 5 B. & S. 372 ; 38 L. T. 201 ; 26 W. K. 413.
570; L. R. 1 Q. B. 149. {d) 4 Met. (Mass.) 49.

master's liability to servants. '.Wi

not cxteiul ti) indcninify tlic sorvaiit against the negligence
of anyone but liiniself ; and he is not liable in tort, as for the
negligence of his servant, because the person suffei'ing does
not stand towards him in the relation of a stranger, but is one
whose rights are regulated, by contract express or implied."

Whatever be the true reason, it has been undisputed law
since the decision of the Exchequer Court in l^ricsthnj v.
Fowler in 1837 (e), that a master is not answerable to one
servant for the conduct of another in the same common
employment. How far this has been altered by legislation
will be subsequently explained ; for the present I state the
Common Law. "The principle is," said Alderson, B., in
Hutchinson V. Yorl-, Newcastle d- Bervjich RaAhvay Co. ( /'),
"that a servant, when he engages to serve a master, under-
takes as between himself and his master, to run all the
ordinary risks of the service ; and this includes the risk of
negligence upon the part of a fellow servant, whenever he is
acting in the discharge of his dut\^ as servant of him who is
the common master of both."

It matters not that the work is dangerous if the dangers be
incidental to the employment. No one is bound to enter or
continue in employment in which he runs serious risk, and
if he does, he must take things as he finds them (/y). •

The master is not the insurer of those whom he employs.
He does not warrant the competency and care of his

(r) 3 JI. i^ AV. 1. liole in the floor, owing to the want

(/) (1850), 5 Ex. 352. of liglit and fencing ; no breach of

(f/) Sec IVigmora v. Jay (1850), duty shown.) This case is open to

5 Ex. 354 ; 19 L. J. Ex. 300. doubr. Skipp v. Eastern Counties

(Action by the administratrix of Rii. Co. (1853), 9 Ex. 223. (A guard

Wigmore under 9 & 10 Vict. c. 93 ; injured ; evidenc'e tliat tlie work was

the deceased, a workman in the too nuich for the stalf of the com-

eniploynient of the defendant, a pany ; the servant liad for several

master builder, liad been killed by niontlis acted as a guard, and had

the fall of a scaffold, constructed under made no eomjilaint : no liability.)

sui>erintendence of defendant's fore- Couch v. Steel (1854), 3 E. »^ 15. 402 ;

man, who used an unsound pole; 23 L. J. Q. 1>. 121. (Xo implied obli-

no cause of action.) Seymour v. gation on the part of the owmer of a

Maddox (1851), 16 (J. I'. 326 ; 20 L. siiip towards a seaman that the ship

J. Q. B. 327. (Action by a cliorus shall be in a lit state to perform the

.singer against defendant, owner of a voyage.) See, however, 39 & 40 Vict,

theatre ; the plaintiff fell through a c. 80, s. 5.


servant (li), thoiigli he Avill expose himself to an action if he
employs those whose incompetency is known to him (/). The
carelessness of a servant in the course of his duties which
results in the injury of another gives no cause of action
against their common employer. A licensed waterman and
lighterman in the employment of a corn merchant is injured
by the fall of a sack owing to the carelessness of one of the
corn merchant's men in hoisting it (/.) ; a miner is killed by
the carelessness of an engineer who does not stop a cage
when it emerges yom the pit, but allows it to be drawn up
to the scaffold (I) ; a workman engaged in erecting scaffolding
falls, and is injured owing to the negligence of the foreman,
who did not supply sufficient boards (771) ; a man employed '
in carpenter's work for a railway company is injured by the
negligence of porters who shift an engine so that it strikes the
scaffold on which he stands (y^). In all these cases the injured
persons or their representatives have at Common Law no
redress against the employers on the ground that the negli-
gence is that of fellow servants.

The servant whose negligence or misconduct is the cause
of the injury may be the superior of the person injured, and
the latter may be bound to obey his orders. He is not the
less a fellow servant. " A merchant's clerk, though (as
is frequently the case) the equal of his employer in social
position, is, in the eye of the law, a fellow servant with the
boy who sweeps out the store and lights the fire (o)."

In Wilson v. Mervu {p) it was held to make no difference
that the accident to men sinking a shaft arose from the

(/t) Sr.>/mo)/r v. Maddox, aiul .Tcrvis, 335.

C.J., in Tarrant v. Welih (ltJ56), 18 (n) Morqan v. Vale of Neath Hi).

C. B. 797. Co. Sco lioto (/-).

(/) See page 316. (o) Slicunnan and lli'dfu'ld on

\k) Loir.n V. Hou-rH (1S7G), L. R. Nt-Kliyunce, s. lOd.

1 C. V. D. 161 ; 45 L. J. C. P. 3S7 ; (//) (1868), L. K. 1 S. & D. 326.

34 L. T. 183 ; 24 W. R. 672. See also Fell/iaiii v. Em/laiui (1866),

{I) Bartvnshill C'ual Co. v. Jieid K. R. 2 (,). 15. 33 ; 7 H. & S. 676 :

(1858), 3 .Macf|. 266. HmceJls v. Landqrc Skel Co. (1874),

{m) Gallaijhrrv. Piper (1S6U, Tl I-. 1!. 10 Q. B. 62.
C. B. N. S. 669; 32 L. J. ('. 1'.

master's liability to si>:rvants. .305

negligence of a manager. Wlien a third engineer, while
turning a winch under tlie orders of the first, was injured by
one of the handles coming off, the owners were not liable,
though the handle came off in consequence of the negligence
of the chief engineer in leaving the machinery in a defective
state (q). [But see the Employers' Liability Act, sees. 2 and .3.]
The Courts have given a very wide signification to fellow
servants. Two classes of cases must be distinguished : (1) Tlie
first consists of cases in which two persons are undoubtedly in
the service of the same master ; and the only question is
whether they arc engaged in common duties or so employed
as to bring them within the rule. No authority goes so far
as to say that the principle holds good between all servants
employed by the same master. If a man owned a farm in
the country and a warehouse in town, and if one of his farm
servants happened to be injured by the negligence of a
servant engaged in the warehouse, no one would say that the
master would be freed from liability (r). A sailor on one
ship would not be regarded as the fellow servant of a sailor
on another, though both ships belonged to the same owner.

(q) Scarlc v. Lindsay (1861), 11 69(5 (dressmaker bitten by a savage

C. B. N. S. 429 ; .8 Jur. N. S. 746 ; dog) ; or if the injury result from

31 L. J. C. P. 106 ; 10 "vY. R. 89 ; 5 the master's negligeTice ; Wavren v.

L. T. N. S. 427 ; also Willes, J., in JVildec (1872), W.' N. 87 (explosion

Gallafjher v. Piper ; IlnurU v. La)i- of gas). But tlu; above exemption

dore Steel Co. (1874), 10 L. R. Q. B. exists in the event of the servant

62 ; 44 L. J. (}. B. 25 ; 23 AV. R. being injured wliile returning from

335. work, if it be part of the contract

('/■) See Blackburn, J., in Morcjan that he is to be conveyed hack, as in

Y. ValeofXcath Rij. (Jo., 33 li. J. Tunney v. Midland ki/. Co. (1866),

Q. B. 260 ; 5 B. & S. 570 ; L. R. 1 L. R. 1 [C. P. 291. See as to this,

Q. B. 149; and Pollock, C.B., in Lord. Bvo\\<ihnm. in L'n/don v. Stewart

Abraham v. Reynolds (1866), 5 H. & (1852), 2 Macq. 30 ; also Packet Co.

N". 143 ; Shearman and Redfield on v. M'Cue (1873), 17 Wall, U. S.

Negligence, s. 101. The exempticm 508. (A. hired to as-;ist in loading a

does not extend to cases where the boat belonging to defendant, lut not

servant, at the time of the injury, is in the general employment of defeml-

not acting in the service of his master. ant. After the job was over, and he

See Alderson, B., in Ifutchinso/i v. was paid, ho was crossing a gang-

Thc York, XrrccaMlc, d; Berwick Pi/- way to go ashore, and was injured by

Co., 5 Ex. 34.3 ; 19 L. J. Ex. 296 ; the negligence of drfend:u'it's ser-

the master isliable if the injury be due vants : a question for the jury whether

to a risk not incident to the service, the relation of master and servant had

Mamfidd V. Baddcley (1876), 34 L. T. ceased at the time of the injury. )



But it is not necessary that servants should be doing the same
or similar acts in order to come within the rule. " The driver
and the suard of a stacfe coach, the steersman and the
rowers of a boat," said Lord Cranworth in B<irtonsJiill
Coal Co. V. Reid{s), "the workman who draws the red-hot
iron from the forge and those who hammer it into shape,
the engine man who conducts a train, and the man who
regulates the switches or the signals, are all engaged in
common work " (t). The duties of two servants may have
little connection, and may rarely bring them together. They
may be of different grades ; they may belong to different
departments of the same factory, workshop, or establishment ;
their occupations may lie far apart (u) ; and they may be
scarcely aware of each other's existence. They may be not
the less felloM' servants. An engineman who controlled the
motions of a cage by Avhich a miner was drawn to the surface
was held to be a fellow servant of a miner engaged below (./■).
Carpenters employed by a railway company to do carpenter's
work and porters engaged in shifting a locomotive (y) ; a miner
and the underlooker of a mine (z) ; a workman and a certifi-
cated manager of a colliery appointed under sec. 2G of the Coal
Mines Regulation Act, the 35 & 3G Vict. c. 76 (a) ; a labourer
employed by a railway company in loading waggons with
ballast and the guard of a train by which he was returning
after doing his work (&), have been held to be fellow servants
in such a sense that an injury committed to the one by the
nefrlicence of the other did not make the master answerable.
Lord Chelmsford, in BarionshUl Cual Co. v. McGidre (c),
suggested that in general a satisfactory conclusion could be
arrived at " by keeping in view what the servant must have

(.«) See note (»•). Ji'.l. Co. (1858), 8 Ir. C. L. 312.

(t) Comjiare remarl<s of Pollock, (;) Hall v. Julinsoii (I860), 3 H.

C. 15., in Abraham v. Jicynolda. & C. 58i).

(m) Shaw, J., in Fariccll v. Tlic (a) Howell v. Landorc Sled Co.

Boaton Ry. Co. (1874), L. K. 10 Q. B. 62 ; 44 L. J.

(x) JkirlonshUl dal Co. v. lie id. (}. V,. 2r> : 2!? W. K. SS.-i.

(y) Morgan v. Vale of Aealh Jli/. {/)) Tiinney v. Midland Hy. Co.

Co. (1864), 5 13. & S. 570 ; L. R."l (1866). L. R.'l C. P. 291 ;12JuV. 691.
Q. B. 149 ; M'Eniry v. JVatcrford (t) (1858), 3 Macq. 308.

master's liability to servants. 'M)7

known or expected to have been involved in the service which
he undertakes,"— a test which, looking- at the authorities, is
scarcely comprehensive enough (d).

In Chaiie^s v. Taylor (e) — which involved the (piestion
whether one of a gang of "lumpers " or men engaged in un-
loading coal barges for the defendants, Avho were brewers,
and servants of the defendants engaged in moving barrels,
were fellow servants — the Common Pleas Division held that
they were such ; and Lord Justice Brett suggested the following
formula : " When the two servants are servants of the same
master, and where the service of each will bring them so far
to work in the same place and the same time that the negli-
gence of one iu what he is doing as part of the v/ork which
he is bound to do may injure the other whilst doing tlie work
whicli he is bound to do, the master is not liable to the
servant for the negligence of the other." These formulpe
seem to show that the test is whether or not the negligence
of a fellow servant is a risk which may reasonably be
expected to be incidental to the employment.

(2). A second class of cases consists of those in which
persons are in one respect the servants of different masters,
and yet for some purpose are regarded as if they were the
servants of the same master. No doubt it is laid down that
to exempt a master there must not only be a common service
or employment, but also a common master. When a signal-
man engaged and paid by one company and wearing their
uniform, but bound to attend also to the trains of another
company, was killed by the neghgence of an engine-driver in
the service of the latter, it was held that they were not in a
common employment (/). Bat the Courts have in some cases
recognised the fact that a man may l)e, in a certain sense,

(d) The principle is thus stated by those managing that traffic is one of

Blackburn, J., Morgan v. Vale of the risks necessarily and naturally

Neath Rij. Co., 5 B. & S. 580 : "1 incident to sucli^an employment, and

think that, whenever the employ- within the rule."

ment is such as necessarily to bring (c) (1868), 3 C. P. D. 496.

the person accepting it into contact (f) Sirain.^onv. North -Eastern Ry.

with the tralticofthe line of a railway, Co. (1878), L. R. 3 Ex. D. 341.
risk of injury from the carelessness of


the servant of two masters, and they have treated as fellow-
servants persons who, in one point of view, were not such,
but were subject to different masters.

The first of these cases is Wiggett v. Fox (,7), the fiicts of
■which were as follows : The defendants, who had contracted
Avith the Crystal Palace Co. to erect a tower, made a sub-
contract with ]\r. and four other persons to do by piece parti-
cular portions of the work. The workmen of the sub-con-
tractors were paid weekly by the defendants according to the
time which they worked. The sub-contractors received from
the defendant's foreman directions as to the execution of the
piecework. The persons who contracted with the defendants
to do piecework, signed printed regulations by which they
were not at liberty to leave their emjDloyment until after they
had completed their piecework, and had given a week's notice.
While W., who was employed by M., one of the sub-contractors,
was at work, a workman in the service of the defendants let
fall a tool, Avhich killed W. The jury found that W. was the
servant of M. The Court of Exchequer held that the defen-
dants were not liable, the deceased and the workman whose
neolio'ence caused the accident being common servants of the
defendants. "Here both the servants were, at the time of
the injury," said Alderson, B., " engaged in doing the common
work of the contractors, the defendants ; and we think that
the sub-contractor and all his servants must be considered as

Online LibraryJohn MacdonellThe law of master and servant. Part I.--Common law. Part II.-- Statute law → online text (page 32 of 77)