Doughty v. Turner Manufacturing Co., Ltd.
England and Wales Court of Appeals
1 Q.B. 1 (1964)
Doughty (plaintiff) sued his employer, Turner Manufacturing (defendant), after a cauldron of molten metal exploded and burned him. A worker had accidentally knocked an asbestos-concrete lid into the molten mixture; witnesses saw no splash and no immediate injury when it slipped in, and two workers even stepped closer to watch. One or two minutes later, the mixture exploded. Later scientific testing revealed that the specific compound in the lid releases water when immersed in molten metal, triggering a chemical reaction that causes an explosion - but nobody at the time knew or could have known this. The trial judge ruled for Doughty, reasoning that Turner should have foreseen that objects falling into the cauldron could cause splashing burns or that some foreign substance might cause an explosion, and should have taken precautions against both. Turner appealed.
Whether a person must take precautions against an event only if it is reasonably foreseeable that the event will cause injury.