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Personal Injury Pleadings 4th edition

AuthorPatrick Curran QC, Victoria Williams, Allan Gore QC
PublisherSweet & Maxwell
ProductPersonal Injury Pleadings 4th edition Hardback+CD£215+VAT

December 2008

Features

Supplying everything you need for settling pleadings in personal injury claims, Personal Injury Pleadings:

  • Includes a comprehensive range of personal injury pleadings from general topics such as occupiers' liability and motorists liability, to specific areas such as liabilities for sports injuries and injuries by animals
  • Lays out pleadings in modern fashion using plain English, updated to reflect the most recent changes to the CPR
  • Provides a selection of defences, paired with specific pleadings
  • Includes guidance on basic considerations to take into account before drafting each type of pleading
  • Offers discussion of relevant case law as it applies to specific types of pleadings
  • Includes relevant legislative provisions, current and legacy, for context and ease of reference
  • Lays out pleading headings alphabetically for ease of use
  • Includes a CD which consists of all pleadings in electronic format, organised by chapter, as per the mainwork

Contents

  • General principles of Personal Injury Pleading
  • Occupiers' Liability
  • Motorists' Liability
  • Liability for Sports Injuries
  • Liability for Animals
  • Highway Authorities' and Public Utilities' Liability
  • Product Liability
  • Assault and Trespass to the Person
  • Private Individual's Liability
  • Clinical Negligence
  • Fatal Accidents
  • Post-1992 Employers' Liability
  • Employers' Liability under pre-1992 legislation
  • Defences
  • Amendments to Pleadings

Reviews

Compresses years of practical experience into an accessible format - a lawyer who expects to draft any personal injury pleading needs ready access to this book.
Counsel - of a previous edition

Complete contents list

Chapter 1—General Principles of Personal Injury Pleadings

1. The Original Woolf Proposals in Respect of Pleadings

2. “Access to Justice”—the Final Report

3. Principles

4. The Pre-Action Protocols

5. Requirements of the Civil Procedure Rules for Pleadings

Forms

Examples of Relevant Endorsements on Claim Forms

Claim by Customer against Occupiers of Superstore for Injuries Caused by

Slipping on Yogurt on Floor

Completion and Conclusion of Claimant’s Statement of Case

Schedule of Past and Future Losses and Expenses

Position Statement on Lump Sum/Periodical Payment Order

Defence to Form F1–002

Counter Schedule of Past and Future Losses and Expenses

Request by Defendant Store Occupiers for Further Information

Response: Further and Better Information in Answer to the Defendants’ Request in Form 1–007 Using Alternative Form of Response

Request for Information (Claim by Customer against Occupiers of Superstore

for Injuries Caused by Slipping on Yogurt on Floor)

Response: Further Information form Defendants (Claim by Customer against Occupiers of Superstore for Injuries Caused by Slipping on Yogurt on Floor)

Limitation Foreman Bricklayer Working with Chemicals Developed Occupational Asthma: Late Diagnosis and Date of Knowledge Pleaded: Pre-Dating Control of Substances Hazardous to Health Regulations 1988

Limitation Raised, Defence to Form F1–012

Reply to Defence in Form F1–013

Claim by Lagger for Provisional Damages for Asbestosis

Legislative Provisions

Limitation Act 1980 ss.10, 11, 11A, 12, 14, 14A, 14B, 28, 33

Fatal Accidents Act 1976: ss.1–5

Law Reform (Miscellaneous Provisions) Act 1934 ss.1

Law Reform (Contributory Negligence) Act 1934 ss.1

Civil Evidence 1968 s.11

Supreme Court Act 1981 ss.32–35A

County Courts Act 1984 s.51

Damages Act 1996 ss.1–3

Civil Procedure Rules Part 7.4 and paras 3.6, 3.8, 6.1–7.3

Part 14 and Practice Direction

Part 15 and Practice Direction

Part 16 and Practice Direction

Part 18 and Practice Direction

Part 20 and Practice Direction

Part 21.10 and Practice Direction paras 5.1–7.4

Part 22 and Practice Direction

Part 41.1–41.7 and Practice Direction

The Damages (Variation of Periodical Payments) Order

Pre-action Protocol for Personal Injury Claims

The Pre-action Protocol for Disease and Illness at Work Claims

Chapter 2—Amendment of Pleadings

Forms

Amended Particulars of Claim: (simple short amendments)

Amended Particulars of Claim: (complex amendments to be marked)

Legislative Provisions

Limitation Act 1980 s.35

Chapter 3—Liability for Injuries Caused by Animals

Introduction

Forms

Claimant Injured by Unpredictable and Dangerous Horse Claimant Employee of First Defendant who was Owner of Vicious Dog. Second Defendant Vet. Dog Operated Upon by Second Defendant, Subsequently Bit Claimant Whilst Helping to Carry the Dog at First

Defendant’s Request. No Warning Given About Anaesthetic or Muzzling Claimant Barmaid Injured when Defendant’s Mischievous Dog Ran into her Causing her to Fall

Minor Riding Horse, Fell Off and Trampled on by another Horse at Riding School

Legislative Provisions

Animals Act 1971

Chapter 4—Assaults and Trespass to the Person

Forms

Assault and False Imprisonment

Claimant Assaulted in His Home: Aggravated Damages Sought

Claimant Assaulted By Store Security Guard: Aggravated Damages Claimed

Parking Inspector Injured by Defendant Driving Motor Car into him

Vicarious Liability—Claim by Child against School as Employers of

Housemaster for Sexual Abuse where Negligence not Alleged

Chapter 5—Clinical Negligence

1. Basic Considerations in Pleading Clinical Negligence Cases

2. Miscellaneous Notes

Forms

Child Claimant Left with Scarring after Cyst Excised from Leg; Wound Infected; Stitches Left in for Too Long

Claimant with Aortic Aneurysm which General Practitioner, Casualty Officer and Orthopaedic Department Failed to Diagnose

Claimant Suffered Foot Drop Following Gynaecological Operation During which Feet were Placed in Stirrups; Failure to Treat Promptly

Operating Staff Mistook Bile Duct for Cystic Duct; Further Operation Required

Claimant Conceived Child Following Sterilisation Operation; Claimant Not Told of the Failure Rate

Claimant with Psychological Condition Fell in Hospital Fracturing Femur; Fracture Undetected; Three Operations Required Leaving Claimant Permanently Disabled

Failed Sterilisation Operation: Partial Occlusion of Tubes

Doctor Failing to Diagnose Acute Bowel Obstruction

Claim against an Optician for Negligent Treatment

Patient Developing Claw Toes after Negligent Treatment of Leg Fracture Negligent Treatment of Wound by Surgeons Resulting in Extensive Infection, Reaction to Antibiotics, Colitis, and Eventual Need for Colostomy

Negligent Diagnosis and Treatment of Disc Prolapse by GP, Resulting in Permanent Impairment in Sensation Below Waist

Claim by Mother of Violent Psychiatric Patient for Injuries Sustained in

Claim Against Specialist Orthopaedic Staff on Behalf of Child Claimant:

Claim by Patient Being Treated for Lump in Breast: Negligent Surgery Resulting in Failure to Remove Lump and Unsightly Scarring; Need for Second Operation

Claim by Mother for Negligent Treatment at Childbirth: Patient who had

Claim by Child for Damages for Scarring Caused by Negligent BCG Injection

Model Form of Order in YM (A Child & Patient by her Mother & Litigation Friend EH) v Gloucestershire Hospitals NHS Foundation

Trust and others; Claim in Respect of Injuries to Mother and Death of Baby During Birth: Excessive Force in use of Keillens Forceps

Legislative Provisions

Pre-action Protocol for the Resolution of Clinical Disputes

Medical Act 1983 ss.1, 2, 30, 34, 47 and 48

National Health Service Act 1977 ss.1, 2 and 3

Dentists Act 1984 ss.1, 2, 14, 15, 37, 38, 39, 40 and 41

Chapter 6— Employers’ Liability Under Pre-1992 or other Obsolescent Regulations

1. Introductory Note

Forms

Asbestos

Shipyard Worker Developing Pleural Plaques from Inhalation of Asbestos Contrary to the Ship Building and Ship Repairing Regulations1960 Prior to May 14, 1970 (Claiming Provisional or Alternatively Full and Final Damages)

Machine Operator Developing Asbestosis from Inhalation of Asbestos Contrary to the Factories Acts 1937 and 1961 before May 14,

1970 (Claiming Provisional or Alternatively Full and Final Damages) Construction Worker Developing Asbestosis due to Exposure to Asbestos Contrary to the Building (Health, Safety and Welfare) Regulations 1948 and/or the Construction (General Provisions)Regulations 1960 and the Construction (Working Places) Regulations 1966 Prior to May 14, 1970 (Claiming Full and Final Damages Alone)

Living Lagger Developing Mesothelioma due to Exposure to Asbestos

Deceased Docker who Died Testate of Mesothelioma due to Exposure to Asbestos Contrary to the Common Law and/or the Occupiers’ Liability

Deceased Mill Worker who Died Intestate of Mesothelioma due to Exposure to Asbestos Contrary to the Asbestos Industry Regulations 1931(also Seeking a Direction Under s.33 of the Limitation Act 1980 to Allow

Asthma

Bricklayer Working with Chemicals Developed Occupational Asthma

Industrial Deafness

Factory Worker: Industrial Deafness from Noise

Vibration Induced White Finger Disease

Tunnel Worker Working with Percussion Instruments Development VWF

Construction (Health, Safety and Welfare)

Claim against an Employer for Damages for Injuries Caused due to Falling Down an Open Manhole, in Negligence and Relying on the Construction (Health, Safety and Welfare) Regulations 1996

Claim Against an Employer for Damages for Injuries Caused by a Fall from Scaffolding, in Negligence and Relying on a Number of the Construction (Health, Safety and Welfare) Regulations 1996

Claim against an Employer for Damages for Injuries Suffered in a Fall from an Unsecured Ladder, in Negligence and Relying on the Construction (Health, Safety and Welfare) Regulations 1996

Claim against an Employer for Damages for Injuries Suffered Relying on the Construction (Health, Safety and Welfare)Regulations 1996

Roofer using Unsuitable Roof Ladder Injured in Fall from Roof Relying on

General Labourer Laying Pipes without Assistance Despite Request: Relying on the Construction (Health, Safety and Welfare)Regulations 1996

Trainee Plasterer Injured by Mobile Tower: Breach of the Construction

Surveyor Fatally Injured by Falling into Unlit and Unguarded Excavation: Relying on the Construction (Health, Safety and Welfare)Regulations 1996

Claim against an Employer for Damages for Injuries Caused by Object

Defences

Defence to a Claim for Non-Malignant Asbestos Condition

Defence to a Fatal Claim for Malignant Asbestos Condition

Defence: Injury from Ladder Slipping on Slippery Floor

Legislative Provisions

Factories Act 1937 ss.1, 4, 26, 47, 103, 106, 107, 108, 151, 152

Factories Act 1961 ss.1, 4, 29, 63, 123, 126, 127

Asbestos Industry Regulations 1931

Asbestos Regulations 1969

Employer’s Liability (Defective Equipment) Act 1969 ss.1, 2

Construction (General Provisions) Regulations 1966 regs 1, 2, 3, 20, 21

Construction (Working Places) Regulations 1961 regs 1, 2, 3, 6

Shipbuilding and Ship-repairing Regulations 1960 regs 1, 2, 3, 4, 48, 51, 53, 76

The Construction (Health, Safety and Welfare) Regulations 1996

Compensation Act 2003 s. 3

Chapter 7— Post-1992 Employers’ Liability

Introduction

Forms

Management of Health and Safety at Work Regulations 1999

Specimen Allegations for Breach if to be Added to Specific Pleadings Below

Health and Safety (Display Screen Equipment) Regulations

Claim Alleging Epilepsy Caused to Word-Processor Operator by Repetitive Work at VDU: Breach of Health and Safety (Display Screen Equipment) Regulations 1992

Claim Against Employer for Damages for Repetitive Strain Injury due to Data Processing, in Negligence, and Relying on the Health and Safety (Display Screen Equipment) Regulations 1992 and the Workplace (Health, Safety and Welfare) Regulations 1992

Manual Handling Operations Regulations

Nurse Injured Lifting Patient: Breach of Manual Handling Operations Regulations 1992

Cardboard Inspector Suffered Carpal Tunnel Syndrome by Repetitive Work: Breach of the Manual Handling Operations Regulations 1992

Claim by Labourer in Respect of Hernia Allegedly Caused by Lifting Heavyweight

Claim Against an Employer for Damages for Injuries Caused by Unsafe Place of Work and Unsafe System of Work, in Negligence and Contrary to the Manual Handling Operations Regulations 1992 and the Work at Height Regulations 2005

Claim Against an Employer For Damages in Negligence for Injuries due to Unsafe System of Work and Negligent Fellow Employee in a Manual Handling Operation

Control of Substances Hazardous to Health Regulations

Foreman Bricklayer Developing Occupational Asthma: Breaches of the

Control of Substances Hazardous to Health Regulations 2002 and the

Workplace (Health, Safety and Welfare Regulations) 1992

Personal Protective Equipment at Work Regulations

Claim Against an Employer for Damages for Injuries Sustained due to Burns from Molten Metal in Negligence and Contrary to the Personal Protective Equipment at Work Regulations 1992, regs 4, 9 and 10

Die-caster Splashed by Molten Metal: Breach of Personal Protective Equipment at Work Regulations 1992 and the Workplace (Health, Safety and Welfare) Regulations 1992

Claim Against an Employer for Damages for Injuries due to Particle Flying into Eye in Negligence and Contrary to the Personal Protective Equipment Regulations 1992, regs 4, 6 and 7

Provisions and Use of Work Equipment Regulations

Laundry Manager’s Hand Caught in Roller of Sheet Press; Post-1998 Case: Breach of Provision and Use of Work Equipment Regulations 1998

Claim Against Employer for Damages for Injuries Sustained In Gaps Between Dangerous Parts of Unfenced Machine, in Negligence and Contrary to the Provision and Use of Work Equipment Regulations 1998, regs 9 and 11

Factory Worker Injured by Rotating Metal Teeth on Glass Hopper; Post-1998 Case: Breach of Provision and Use of Work Equipment Regulations 1998

Jig Maker’s Finger Injured in Circular Saw; Post-1992 Case: Breach of Provision and Use of Work Equipment Regulations 1992

Trainee Hairdresser Burned by Defective Lamp: Claim Alleging Breach of the Provision and Use of Work Equipment Regulations 1998 and the Electrical Equipment (Safety) Regulations 1994

Ordnance worker Injured by Beryllium Dust; Breach of Provision and Use of Work Equipment Regulations 1998 and the Workplace (Health, Safety and Welfare) Regulations 1992 and Failure to Provide Proper Medical Care

Claim against an employer for damages for injuries sustained as a result of piece of grinding wheel being ejected into eye, contrary to the Provision and Use of Work Equipment Regulations 1998 and the Personal Protective Equipment at Work Regulations 1992 and Relying on the Employers Liability (Defective Equipment) Act 1969

Operator’s hand crushed by power press; breach of Provision and Use of Work Equipment Regulations 1998

Claim Against Employer for Damages for Injuries Sustained as a Result of Unsafe System of Work, Insufficient Plant and Equipment and Inadequate Training, Contrary to the Provision and Use of Work Equipment Regulations 1998 and in Breach of the Lifting Operations and Lifting Equipment Regulations 1998 and in Negligence

Claim Against Employer for Damages for Injuries Sustained as a Result of Unsafe System of Work, Insufficient Plant and Equipment and Inadequate Training, Contrary to the Provision and Use of Work Equipment Regulations 1998 and in breach of the Lifting Operations and Lifting Equipment Regulations 1998 and Work at Height Regulations 2005 and in negligence

Claim for damages against employer for injuries sustained when the seat on which he was sitting collapsed, contrary to the Provision and Use of Work Equipment Regulations 1998 and the Workplace (Health, Safety and Welfare) Regulations 1992

Claim for injuries sustained while trying to repair machinery, in breach of the Provision and Use of Work Equipment Regulations 1998

Claim against employer for damages for injuries caused by defective equipment, in negligence and for breach of the Provision and Use of Work Equipment Regulations 1998 and the Employers Liability (Defective Equipment) Act 1969

Claim against an employer for provisional damages due to dangerous condition of lorry, in negligence, relying on the Employers Liability (Defective Equipment) Act 1969, s.1, and relying on the Occupiers’ Liability Act 1957, s.2 and the Provision and Use of Work Equipment Regulations 1992, regs 5, 6 and 12 and Work at Height Regulations 2005 reg.10

Technician injured by blades falling out of mitre saw contrary to the Provision and Use of Work Equipment, regs 4, 5, 6, 11 and 12

Injury from ladder slipping on slippery floor relying on the Workplace (Health, Safety and Welfare) Regulations 1992, the Work at Height Regulations 2005 and the Provision and Use of Work Equipment Regulations 1998

Caretaker injured by slipping ladder relying on the Provision and Use of Work Equipment Regulations 1998 and the Work at Height Regulations 2005

Workplace (Health, Safety and Welfare) Regulations

Claim Against Employer for Damages for Contracting Dermatitis or Similar Condition, in Negligence and Contrary to the Personal Protective Equipment at Work Regulations 1992 and the Workplace (Health, Safety and Welfare) Regulations 1992

Nurse in Hospital Tripping Over ECG Wires Alleging Breach of the Workplace (Health, Safety and Welfare) Regulations 1992

Manageress of Shop Injured when Step Stool Wobbled Causing Fall, Alleging Breach of the Workplace (Health, Safety and Welfare) Regulations 1992 and the Work at Height Regulations 2005 and in Negligence

Claim Against Employer for Damages for Injuries Sustained due to Defective Step/Floor in a Factory, in Negligence and Contrary to the Workplace (Health, Safety and Welfare) Regulations 1992 and the Provision and Use of Work Equipment Regulations 1998

Claim Against Employer for Damages for Injuries Sustained due to Slipping on Liquid on Floor in Factory, in Negligence (Including of Fellow Employees) and Contrary to the Workplace (Health, Safety and Welfare) Regulations 1992 and the Personal Protective Equipment at Work Regulations 1992

Claim Against Employer for Injuries Sustained in Factory due to Tripping over Raised Edge, in Negligence and Contrary to the Workplace (Health, Safety and Welfare) Regulations 1992

Claim Against Factory Occupier other than the Claimant’s employer, for Damages for Injuries Sustained due to Treading on an Object Lying on the Floor, in Negligence and Contrary to the Workplace (Health, Safety and Welfare) Regulations 1992

Claim Against Employer for Damages for Injuries Sustained due to the Effect of Obstruction in Yard on the Steering of a Fork Lift Truck, in Negligence and Contrary to the Workplace (Health, Safety and Welfare) Regulations 1992

Fork Lift Truck Driver Drove Over Plastic Drum which Burst and Sprayed Corrosive Liquid: Breaches of Workplace (Health, Safety and Welfare) Regulations 1992

Machine Assistant Injured by Fork Lift Truck Driven by Fellow Employee

Factory Worker Fell Into Pit and Injured by Machinery: Breach of the Workplace (Health, Safety and Welfare) Regulations 1992 and the Work at Height Regulations 2005

Draughtsman Fell Down Unguarded and Unlit Drop

Waitress Slipping on Highly Polished Floor Relying on the Workplace (Health, Safety and Welfare) Regulations 1992 and the Occupiers’ Liability Act 1957

Factory Worker Slipping on Ice/Snow at Exit to Factory Relying on the Workplace (Health, Safety and Welfare) Regulations 1992

Fireman Slipping on Highly Polished Stairs Relying on the Workplace (Health, Safety and Welfare) Regulations 1992 and the Occupiers’ Liability Act 1957

Factory Clerk Injured by Exposed Metal Strip on Stairs Relying on the Workplace (Health, Safety and Welfare) Regulations 1992 and the Occupiers’ Liability Act 1957

Diseases and Conditions

Claim Against an Employer for Damages due to Occupational Exposure to Asbestos in Negligence and Breach of the Control of Asbestos at Work Regulations 1987

Claim Against an Employer for Damages due to Occupational Exposure to Asbestos in Negligence and Breach of the Control of Asbestos at Work Regulations 2002

Claim Against an Employer for Damages due to Occupational Exposure to Asbestos in Negligence and Breach of the Control of Asbestos Regulations 2006

Claim Against an Employer for Damages for Noise Induced Deafness, in Negligence and Contrary to the Noise at Work Regulations 1989, regs 4, 6, 7, 8, 9 and 11

Claim Against an Employer for Damages for Noise Induced Deafness, in Negligence and Contrary to the Noise at Work Regulations 1989 and the Control of Noise at Work Regulations 2005

Claim Against an Employer for Damages for Hand Arm Vibration Syndrome (‘HAVS’), in Negligence, Contrary to the Control of Vibration at Work Regulations 2005, and Earlier Applicable Regulations

Claim for Excessive Exposure to Radiation Contrary to the Ionising Radiations Regulations 1999, regs 8, 10, 11, 14 and 26

Claim for Provisional Damages for Exposure to a Biological Agent (HIV) Relying on Schedule 3 Part 1 of the Control of Substances Hazardous to Health Regulations 1999

Claim for Provisional Damages for Exposure to a Hazardous Substance

Claim for Exposure to Lead Relying on the Control of Lead at Work Regulations 1998

Construction (Design and Management) Regulations

Claim Against an Employer for Damages for Injuries Caused due to Falling Down an Open Manhole, in Negligence and Relying on the Construction (Design and Management) Regulations 2007

Claim Against an Employer for Damages for Injuries Caused by a Fall from Scaffolding, in Negligence and Relying on a Number of the Construction (Design and Management) Regulations 2007 and the Work at Height Regulations 2005

Claim Against an Employer for Damages for Injuries Suffered in a Fall from an Unsecured Ladder, in Negligence and Relying on the Construction (Design and Management) Regulations 2007 and the Work at Height Regulations 2005

Claim Against an Employer for Damages for Injuries Suffered Relying on the Construction (Design and Management) Regulations 2007

Claim Against an Employer for Damages for Injuries Suffered During Emergency Exit Relying on the Construction (Design and Management) Regulations 2007

Roofer Using Unsuitable Roof Ladder Injured in Fall from Roof Relying on Construction (Design and Management) Regulations 2007

General Labourer Laying Pipes Without Assistance Despite Request: Relying on the Construction (Design and Management) Regulations 2007

Surveyor Fatally Injured by Falling into Unlit and Unguarded Excavation: Relying on the Construction (Design and Management) Regulations 2007 F7–063

Claim Against an Employer for Damages for Injuries Caused by Object Falling from Scaffolding Relying on the Construction (Head Protection) Regulations 1989 and the Construction (Design and Management) Regulations 2007

Miscellaneous Precedents

Claim by Employee Injured by Load Falling from Crane Relying on the Lifting Operations and Lifting Equipment Regulations 1998, regs 4, 7, 8, 9 and the Provision and Use of Work Equipment Regulations 1998, regs 4, 5, 6, 8, 9 and 12 and the Work at Height Regulations 2005 reg.10

Claim Against an Employer for Damages for Injuries Caused by Electric Shock, in Negligence and Relying on the Electricity at Work Regulations 1989, regs 7 and 12 and the Electrical Equipment (Safety) Regulations 1994, reg.5

Claim Against an Employer for Damages for Injuries Caused by Burns, in Negligence and Relying on the Gas Safety (Installation and Use) Regulations 1998, regs.3, 4, 5, 6, 8, 35 and the Workplace (Health, Safety and Welfare) Regulations 1992

Claim Against an Employer for Damages for Injuries Caused by the Failure of a Chair, in Negligence (Unsafe Plant and Equipment and Unsafe System of Work and Negligent Fellow Employee Relying on the Employers’ Liability (Defective Equipment) Act 1969, s.1) and the Workplace (Health, Safety and Welfare) Regulations 1992

Domestic at a Hospital Injured by Hypodermic Needle Projecting from Refuse Bag, Relying on the Workplace (Health, Safety and Welfare) Regulations 1992, regs 5 and 9 and the Occupiers’ Liability Act 1957

Nursing Assistant Attacked by Violent Patient

Fitter Injured by Pipe from Hydraulic Pressure System Blowing Apart, Relying on the Pressure Systems Safety Regulations 2000

Claim by a Dock Worker for Injuries Sustained whilst Unloading Cargo: Breach of Docks Regulations 1988

Claim by Merchant Seaman for Injuries Sustained whilst Working Afloat: Breach of the Merchant Shipping and Fishing Vessels (Health and Safety at Work) Regulations 2007

Claim by Dock Worker for Injuries Sustained whilst Unloading Fish: Breach of the Loading and Unloading of Fishing Vessels Regulations1988

Train Driver Injured due to Collision with Buffer Stops: Breach of the Railway Safety (Miscellaneous Provisions) Regulations 1997, the Provision and Use of Work Equipment Regulations 1998, and the Railway Safety Regulations 1999

Mines and Quarries

Mine Deputy Injured by Metal Pipes Slipping from a Cage Relying

on the Management and Administration of Safety of Health at

Mines Regulations 1993

Collier Injured when Foot went Through Damaged Cover Board Relying on the Mines (Safety of Exit) Regulations 1988

Deputy at Coal Mine Injured by Falling Rock/Stone Relying on the Management and Administration of Safety and Health at Mines Regulations 1993 the Mines (Safety of Exit) Regulations 1988 and the Mines (Control of Ground Movement) Regulations 1999

Face worker at Mine Slipping on Rollers Concealed by Slurry Relying on the Management and Administration of Safety and Health at Mines Regulations 1993 and the Mines (Safety of Exit) Regulations 1988

Collier Struck by Stone Falling from Roof Underground Relying on the Management and Administration of Safety and Health at Mines Regulations 1993 and the Mines (Control of Ground Movement) Regulations 1999

Haulier Injured Falling into Coal Chute; Relying on sections 86 and 87 of the Mines and Quarries Act 1954

Quarry Worker Injured by Falling Rock Relying on the Quarries Regulations 1999 regulations 6, 12, 30 and 32

Defences: post–1992 Regulations and general employers’ liability

Defence: Standard Allegations Commonly Encountered

Defence Admitting Negligence and Some Damage

Defence Admitting Negligence but not Damage

Defence Denying Negligence and Damage

Defence to Data Processing Claim Denying Causation, Alleging Proper System of Breaks and Changes of Activity, and Relying Upon Guidance Notes: Defence to Form F7–002

Nurse Injured Lifting Patient: Defence Alleging Steps Taken so far as Reasonably Practicable to Avoid the Need for Manual Handling; and in the Alternative, Alleging Suitable and Sufficient Assessment of Operations and Taking of Appropriate Steps to Reduce Risk: Defence to Form F7–003

Labourer Injured when Pallet Used as a Step Broke; Breach of Workplace (Health, Safety and Welfare) Regulations 1992 alleged; Defence Denying Application of Regulations and Alleging Contributory Negligence: Defence to Claim Similar to Form F7–032

Laundry Manager’s Hand Caught in Roller of Sheet Press; Denying Application of Regulations and Alternatively Maintaining that a Guard was Provided: Defence to Form F7–013

Dye Caster Splashed by Molten Metal; Defence Under Personal Protective Equipment at Work Regulations Alleging Provision of Suitable Personal Protective Equipment, Information, Instruction and Training: Defence to Form F7–011

Defence Admitting Applicability of Regulations and Denying Negligence and Breach of Statutory Duty and Alleging the Taking of Reasonably Practicable Steps to Ensure Safety Under Workplace (Health Safety and Welfare) Regulations

Defence Admitting Applicability of Regulations and Admitting Fact and Circumstances of Accident, Asserting it to have been the Fault of the Claimant for Breach of Statutory Duty

Defence Alleging that the Injury at an Unfenced Machine was due to an Uncovenanted Stroke that was Unforeseeable or Alternatively due to Latent Defect of the Machine: Defence to Claim Similar to Form F7–015

Defence Denying that Weight Manoeuvred was Excessive or Likely to Cause Injury and Alleging that Injury was due to an Unknown Weakness or Susceptibility of Claimant: Defence to Form F7–006

Defence Denying Liability for a Slipping Accident and Alleging that the Accident was due to Independent Contractors Reasonably Entrusted to Cleaning Task in Hand: Defence to Form F7–034

Defence Denying Negligence and Breach of Statutory Duty, and Alleging the Taking of All Reasonably Practicable Steps to Ensure Safety and Alleging Contributory Negligence for Failure to Keep a Look out: Defence to Form F7–034

Defence Alleging Volenti Non Fit Injuria and Contributory Negligence and Breach of reg.14 of the Management of Health and Safety at Work Regulations 1999 Against the Claimant for Having Deliberately Removed the Guard Over a Dangerous Part of Machinery: Defence to Claim Similar to Form F7–013

Defence Denying Liability and Alleging Accident due to Deliberate act of a Fellow Employee Acting Outside the Course of his Employment: Defence to Form F12–039

Defences: employers’ liability (other than cases involving the 1992 Regulations)

Defence to Claim by Engineer Allegedly Injuring Back while Trying to Close Stiff Door on Lift

Injury from Ladder Slipping on Slippery Floor

Draughtsman Falling Down Unguarded and Allegedly Unlit Drop—Defence Alleging that all Reasonably Practicable Steps had been Taken

Foreman Killed by Fellow Employee’s Alleged Negligent Driving of Earth Moving Machine

Boiler Maker Injured by Spanner used by Fellow Employee; Denial that Employee was also Employed by the Defendants; Allegation that Employee was Employed by Another Company

Explosion Causing Fatal Accident: Widows Claim Under Fatal Accidents Act—Defendants Denying Causation and Alleging Contributory Negligence by Deceased

Defence to Claim Against an Employer for Damages for Injuries Suffered in a Fall From an Unsecured Ladder Alleging Contributory Negligence and Breach of Statutory Duty Relying on the Construction (Design and Management) Regulations 2007 reg.14 and the Work at Height Regulations 2005 reg.14: Defence to Form F7–058

Defence to Claim Against an Employer for Damages for Noise induced deafness denying causation and alleging breach of statutory duty and Contributory Negligence Contrary to the Control of Noise at Work Regulations 2005 reg.8 and Management of Health and Safety at Work Regulations 1999 reg 14: Defence to Form F7–050

Legislative Provisions

Management of Health and Safety at Work Regulations 1999

Workplace (Health, Safety and Welfare) Regulations 1992

Personal Protective Equipment at Work Regulations 1992

Manual Handling Operations Regulations 1992

Health and Safety (Display Screen Equipment) Regulations 1992

Lifting Operations and Lifting Equipment Regulations 1998

Control of Substances Hazardous to Health Regulations 2002

Construction (Design and Management) Regulations 2007

Work at Height Regulations 2005

Construction (Head Protection) Regulations 1989

Control of Noise at Work Regulations 2005

Control of Asbestos at Work Regulations 2006

Control of Lead at Work Regulations 1998

Control of Vibration at Work Regulations 2005

Electricity at Work Regulations 1989

Electrical Equipment (Safety) Regulations 1994

Gas Safety (Installation and Use) Regulations 1998

Subordinate Provisions

Pressure Systems Safety Regulations 2000

Docks Regulations 1988

Railway Safety (Miscellaneous Provisions) Regulations 1997

Railway Safety Regulations 1999

Ionising Radiations Regulations 1999

Loading and Unloading of Fishing Vessels Regulations 1988

Merchant Shipping and Fishing Vessels (Health and Safety at Work)

Mines and Quarries Act 1954 ss.86–88

Mines (Safety of Exit) Regulations 1988

Management of Safety and Health at Mines Regulations 1993

Mines (Control of Ground Movements) Regulations 1999

Quarries Regulations 1999

Chapter 8—Fatal Accidents Claims

Introductory Note

Forms

Claim on Behalf of the Estate of Car Passenger Killed in Road Traffic Accident (Civil Partners and Their Children, Adaptable for Married Spouses)

Claim on Behalf of the Estate of Pillion Passenger Killed in Road

Traffic Accident

Doctor Failing to Diagnose Acute Bowel Obstruction

Chapter 9—Highway Authorities’ and Public Utilities’ Liability

1. Highways: Matters to be Pleaded

Forms

Claims

Pedestrian Injured Falling Down Unlit Steps as a Result of Water Authority Severing Power Cable to Street Lighting—Highway Authority and Water Authority Sued

Claimant Injured in Trip on Defective Steps in Highway; Breach of s.41 Highways Act 1980

Claimant Injured in Trip Over Manhole Cover Projecting Above Level of Road Surface at Roundabout

Claimant Injured on Broken, Uneven and Slippery Footpath

Claimant Injured in Fall Over Concrete Bollard Left on Pathway; Electricity Board Joined as Second Defendants

Claimant Injured in Walking Into/Over Metal Fence Which Had Fallen Over Pathway

Claimant Injured in Fall Over Projecting Tree Stump Left in Pavement

Claimant Injured as a Result of Bad Construction, etc., of Paved Area—too Steep for Pedestrians and in Breach of British Standard

Child Cyclist Skidding on Loose Chippings Caused by Defendants’ Road Repairs: no Warning Of Hazard

Claimant Falling into Hole in Road Made by Independent Contractors’ Excavations: Alternative Claim Against Housing Authority as Occupiers

Open Air Street Market; Claimant Injured in Trip on Rope or Cord Left on Highway by Third Defendant Market Stall Holder; Second Defendants Organisers of Market with Consent of First Defendants Highway Authority F9–011

Claimant Injured in Fall Caused by Pothole in Surface of Pavement

Road Accident Caused by Ice: Defendant Highway Authority Failing to Salt or Grit Road

Claimant Injured by Fall Over Dwarf Wall Extending Across Part of Highway

Defences

Defence to Claim in Simple Highway Tripping Case: Statutory Defence Pleaded

Claimant Injured in Trip on Steps in Highway; Denial of Breach of Statutory Duty of Significant Danger: Statutory Defence Under s.58(1) of the Highways Act 1980 Pleaded: System of Inspection Relied Upon: Contributory Negligence Alleged: Defence to Form F9–002

Claimant Injured in Trip on Steps in Highway: Denial of Breach of Statutory Duty or Significant Danger: Fault on Part of Water Authority as Statutory Undertaker Pleaded: Contributory Negligence Alleged: Alternative Defence to Form F9–002

Claimant Motor Cyclist Injured in Collision with Manhole Cover Projecting Above Level of Road Surface at Roundabout: Defence Alleging Vandalism: Defence to Form F9–003

Road Accident Caused by Ice: Defence Alleging Prompt Action Taken by Highway Authority: Defence to Form F9–01

Claimant Injured in Trip on Steps in Highway: Denial of Breach of Statutory Duty or Significant Danger: Defence to Form F9–002

Claimant Injured as a Result of Gas Board Leaving Unguarded Trench in Highway: Gas Board Alleging Fault of Highway Authority: Defence to Form F9–012

Legislative Provisions

Highways Act 1980 ss.41, 58 and 329

New Roads and Street Works Act 1991 ss.48–60, 65–73, 73F, 79–86,

94, 95 and Sch. 3

Chapter 10—Motorist’s Liability

1. Introductory Note

Forms

Claims

Claim by Driving Instructor for Whiplash Injuries Sustained When

Defendants Drove into Rear of Claimant’s Stationary Car Whilst

Claimant Supervising Pupil

Motor Car Driver Disobeying Traffic Signal and Colliding with Motor

Cycle Rider

Defendant Negligently Drove Motor Car into Motor Cyclist

Child Suing Estate of Deceased Driver of Motor Car who Ran Over Claimant While Claimant Crossing Road

Head On Collision Case

Defendant Car Driver Colliding With Parked Vehicle; Excess Alcohol Defendant Failing to Obey Pelican Crossing Signals and Colliding With Rear of Claimant’s Car Stationary at Crossing

Claimant Passenger Injured in Vehicle Driven with Inadequately Maintained Brakes

Claimant Run Over on Pedestrian Crossing

Claim for Approval of Settlement of Claim by a Child

Assault Case; Claimant Leaning Into Defendant’s Car When Defendant Drove Off Dragging Claimant Away

Police Officer Negligently Driving Into Collision With Claimant’s Car

“Shunt” Accident Caused by Defendants’ Vehicle Being Driven Into Vehicle Which Struck Claimant’s Car

Traffic Light Case

Coach Driver’s Negligence

Passenger’s Claim for Injuries Received as a Result of Negligent “U-turn”

Defendant Crossing Central Reservation on Dual Carriageway and Negligently Driving Car Into Claimant ‘s Car

Claimants Knocked Down on Pedestrian Crossing

Lorry Collided with Rear of Motor Car on Motorway

Defendant Drove into Road Sign, Which Struck the Claimants’ Motor Car, and Then Drove into the Claimants’ Car

Accident on Approach to Road Junction

Accident on Motorway

Defendant Changed Lanes in the Path of On-Coming Motor Cycle

Public Service Vehicle Failing to Give Way at Junction

Road Traffic Accident; Claim Against Personal Representatives of Deceased Driver

Head On Collision

Claim against Motor Insurers’ Bureau

Elderly Person Struck by Reversing Car

Claim by Cyclist Injured When Driver of Car Negligently Opened Door in his Path

Collision Following Defendant Emerging From a Minor Road into Claimant’s Path

Claim on Behalf of the Estate of Pillion Passenger Killed in Road Traffic Accident

Form of Pleading for Joinder of MIB in an Uninsured Driver Case

Fatal Road Accident Case: Allegation of Use of Mobile Phone When Driving

Legislative Provisions

Road Traffic Act 1988 ss. 2, 2A, 3, 3A, 5, 11, 14, 16, 22, 35, 36, 38, 41 and 53

Road Vehicles (Construction and Use) (Amendment) (No.4) Regulations 2003

The Highway Code 2007 (extracts)

The Zebra, Pelican and Puffin Pedestrian Crossings Regulations

and General Directions 1997 (SI 1997/2400)

Chapter 11—Occupiers’ Liability

1. Basic Considerations

2. Statutory Provisions

3. Miscellaneous Notes

Forms

Claims against Shops

Claim by Personal Representative of Deceased Pedestrian Injured in Fall Over Single Step in Indoor Market, Including Allegation of Failure to Follow British Standard

Claim by Customer Against Superstore for Injuries Caused by Tripping Over Low-Loader Trolley Left in Aisle

Claim by Customer Against Shop Owner for Injuries Caused by Slipping on Wet Floor

Claim Against High Street Chemist for Tripping Accident Caused by Defect in Exterior Surface Adjoining Pavement

Claim by Child Against Superstore for Injuries Caused by Fall From Shopping Trolley, Including Claim Under the Defective Premises Act 1972

Claim by shopper Injured by Collapse of Defective Chair in Furniture Shop

Claim by Pedestrian Against Shop Owner for Injuries Caused by Shop Sign Falling in Highway

Public Parks and Playgrounds, shopping Centres and Car Parks

Claim by Child Against Council Occupiers of Park for Injuries Received as a Result of Stepping into a Pothole in a Path

Claim by Child Against Council as Occupiers of Playground for Injuries

Claim by Child for Injuries Received Whilst Using Slide at Defendant’s Playground

Claim by Child for Injuries Caused by Tripping in Council Car Park Including Claim Against Council as Highway Authority

Claim by Pedestrian Against Council as Occupiers of Shopping Centre (and Against Architects Thereof) for injuries Received in Fall Whilst sitting on dangerously low wall, including allegations of failing to Comply with Building Regulations

Claim by Visitor to Leisure Centre Against Council Occupiers for Injuries Caused When Walking on Defective Temporary Step

Claim by Mother and Child Against Council for Injuries Caused in Fall on Dangerous Steps at Council Offices

Claim by Child, Injured After Falling at Ice Rink: Inadequate Supervision

Schools and Colleges

Claim by Student Against Occupiers of Training Centre for Injuries Received in Fall Caused by Slipping on Wet Surface of Corridor Leading to Canteen

Claim by Mother of Child Against School Authority for Injuries Caused by Slipping on Wet Floor Tiles at School

Claim by Child Against Council Education Authority for Injuries Received at School During Physical Education Lesson in Falling From Climbing Frame: Breach of Education (School Premises) Regulations 1981 and Inadequate Supervision Alleged

Claim by Child Against Council Education Authority for Injuries Caused by Finger Catching in Dangerous Gate. Breach of Education (School Premises) Regulations 1981

Claim by Child Against Council School Authority for Injuries Caused

by Dangerously Steep Bank Including Allegations of Lack of Supervision

and Failure to Follow British Standards

Claim by Dining Room Assistant for Injuries Sustained by Slipping on

Water in Corridor

Prisons and Places of Definition

Claim by Young Offender Detainee Against Home Office for Injuries Caused by Dangerous Laundry Machine

Claim by Prisoner Against Prison and Pest Control Contractors for Injuries Sustained Through Inhaling Dangerous Fumes

Claims against Contractors as Site Occupiers

Claim by Pedestrian Against Construction Company Occupying Building Site Crossed by Public Footpath

Claims against Clubs

Claim by Guest Against Club Trustees for Injuries Caused by Beer Glass Falling from Table Whilst Attending an Engagement Party

Claim by Visitor to Rugby Ground for Injuries Caused in Fall on Grandstand Staircase After Workmen Removed Steps

Claim by Visitor Against Night Club Owner for Injuries Caused by Fall Over Single Step Leading to Ladies Lavatory

Garages, Car Showrooms

Claim by Customer Against Garage Proprietors for Injuries Caused by Slipping on Oil Within Garage Premises

Claims against Neighbours

Claim by Visitor to Second Defendant’s Home Against Next Door Neighbour (First Defendant) and Second Defendant for Injuries Received in Falling into an Unguarded Excavation Made by First Defendant at Boundary Between the Gardens of the Defendants’ Properties

Claim Against Neighbour for Injuries Received as a Result of the Collapse of Neighbour’s Boundary Wall

Claims by Police Officers Entering Premises

Claim by Police Officer Injured Tripping Over Dangerously Low Boundary Wall Between Council Houses Whilst Investigating Incident, Including Allegation of Failure to Follow British Standards

Claim by Police Officer Against Occupiers of Dwelling-House for Injuries Received in Falling into an Unguarded and Unmarked Manhole at the Side Thereof

Claims by Council House Tenants

Claim by Council Tenant for Breach of Statutory Covenant to Repair and Negligence Causing Respiratory Infection and Asthma to Tenant and her Children

Claim by Council Tenant Against Council as Landlord and Highway Authority For Injuries Caused By Defective Steps Leading from Road to House

Claim by Council House Tenant for Injuries Caused by Collapse of Front Garden Wall

Claim by Council House Tenant for Discomfort and Inconvenience Caused by Incompetent Execution of Repair Works

Claim by Council Tenant for Breach of Statutory Covenant and Negligence Caused by Excessive Damp after Explosion Caused Damage to Water, Heating or Drainage Pipes

Claim by Council Tenant and Child for Asthma Caused by Damp Resulting from Breach of Statutory Covenant and Negligence/Breach of Defective

Premises Act 1972

Claim by Disabled Council Tenants Against Council Landlord for Respiratory Ailments Caused by Inadequate Heating and Excessive Damp Resulting from Breach of Statutory Covenant and Negligence/Breach of Defective Premises Act 1972

Claim by Tenant Against Council and Contractors for Injuries Caused by Defective Steps Forming Part of the Common Parts of a Block of Flats

Claim by Tenant Against Council for Injuries Caused by Fumes Emitted from Defective Heating System

Claims by Tenants against Private Landlords

Claim by Tenant for Breach of Statutory Covenant for Repair Causing Penetrating Damp and Personal Injury

Claim by Artist Against Landlords of Studio for Injuries Caused by Fall from Defective Step Ladder Provided by Landlords

Hospitals

Claim by Hospital Porter For Injuries to Eyes Caused by Careless Disposal

of Irritant Liquids

Holiday Centres, Caravan Parks

Claim by Child Against Owners of Holiday Caravan Park for Injuries Caused by Defective Steps to Caravan

Claim by Holidaymaker Injured by Dangerous Chair in Ballroom of Holiday Camp

Claim by Child Falling from Dangerous Bunk in Caravan

Legislative Provisions

Occupier’s Liability Act 1957

Occupier’s Liability Act 1984

Landlord and Tenant Act 1985

Defective Premises Act 1972

Chapter 12—Private Individuals’ Liability

Forms

Claims

Motorcyclist Injured When He Drove into Chippings Dumped in Highway Causing Obstruction

Claimant Tripped Over Length of String Left Across Pavement by Building Contractors

Defendant and Claimant Owners of Adjoining Properties; During a Gale a Roll of Foam Blew by Gale from Defendants’ Back Yard and Hit Claimant

Defendant Plumber Parked His Van Outside Claimant’s House; Van Exploded Injuring Claimant

Claimant Employee of First Defendant Who Was Owner of Vicious Dog F12–004/1

Claimant Barmaid Injured When Defendant’s Dog Ran Into Her Causing Her To Fall

Claimant Injured by obstructions Projecting From Defendant’s Trailer and Vehicle Left On Road

Claimant Struck by Jib of Crane Operated by Defendant Building Contractor

Window Cleaner Injured Falling Off Ladder

Claimant Injured Falling on Defective Pavement Outside Private Residence

Defences

Claimant Barmaid Injured When Defendant’s Dog Ran into Her; Defence Denying that the Dog Was of a Mischievous or Abnormal Nature: Defence to Form F12–004/2

Defendant and Claimant Owning Adjoining Properties: Roll of Foam Blowing from Defendant’s Back Yard and Striking Claimant (Claim in Nuisance and Negligence): Defence Denying Negligence and Pleading that Nuisance was Caused by a Burglar: Defence to Form F12–003

First Defendant’s Dog Biting Claimant After Operation Having Been Defendant Denying Negligence and Asserting Warnings: Defences of the First and Second Defendants to Form F12–004/1

Chapter 13—Product Liability

Introduction

Forms

Claims

Claimant Suffered Electric Shock from Hi-Fi Appliance

Claim for Damages for Injuries Caused by Blade of Defectively-Packaged Food Mixer

Claim for Damages for Personal Injuries Caused by Defective Automatic Transmission System

Nursing Auxiliary Struck by Defective Counter-Weighted Support Bar Manufactured by Second Defendants

Claim Against Pharmaceutical Company for Addictive Properties of Drug

Windscreen Shattering Spontaneously: Motorist Injured

Hairdresser’s “Own-Brand” Hair Dye Causing Dermatitis to Customer

Lemonade—Mould in Bottle Causing Gastro Enteritis

Cola Drink—Bottle Exploding in Claimant’s Hand

Customer Injured by Exploding Glass Jar

Conflagration Caused by Gas Escaping from Defective Butane Gas Cylinder

Defence

Defence to a Horseman’s Claim Following Head Injury Allegedly Caused by Defective Riding Helmet

Defence Denying Defective Design or Manufacture of Hi-Fi Appliance and Alleging Faulty Fitting of Plug by Claimant: Defence to Form F13–001

Soft Drink Manufacturers’ Defence to Claim on Behalf of Child

Claimant in Respect of Injuries Caused by Exploding Bottle: Raw Material Suppliers’ Defence Under s.4(1)(f): Defence to Form F13–009

Windscreen Shattering Spontaneously: Defence Under s.4(1)(d): no Defect at Relevant Time: Defence to Form F13–006

Legislative Provisions

Consumer Protection Act 1987

Chapter 14—Liability for Sports Injuries

Forms

Amateur Boxer Sustaining Unnecessary Brain Damage Consequent to Injuries Received During Bout Fought Under Defendant Board’s Rules

Soccer Player Receiving Broken Leg in Dangerous Late Tackle by Opponent

Rugby Player Suing Referee for Injuries Sustained in Consequence of Failure to Enforce Rules

Chapter 15—Summary Assessment of Costs

Introduction

Forms

N260 Form for summary assessment

Materials

CPR Rule 43.3

CPR Costs Practice Direction paras 3.1, 13, 14 and 20.3

Guide to the Summary Assessment of Costs

Product details

Purchase

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