Stanley v Powell

Case Name: Stanley v Powell

Plaintiff: Stanley

Defendant: Powell

Facts of Stanley v Powell

In the case of Stanley v Powell, heard in the Court of Appeal (Civil Division) in 1891, the central issue was whether the defendant, Powell, was liable for the injury sustained by the plaintiff, Stanley, during a shooting party. Stanley was injured when a shot fired by Powell ricocheted off a tree and struck him in the eye.

The injury was deemed accidental, with no evidence of negligence on Powell’s part. Initially, a jury found Powell not to be acting negligently and awarded Stanley £100 in damages. However, upon agreement by both parties, the case was referred to the judge for a final decision.

Issue Raised

Whether the defendant was liable for the plaintiff’s injury caused by a shot fired from the defendant’s gun, even though the injury was accidental and not due to the defendant’s negligence or intentional act.

Arguments

• The plaintiff argued that the defendant should be liable because the injury was caused by a shot fired from the defendant’s gun.
• The defendant argued that he was not liable because the injury was accidental and not caused by his negligence or intentional act.

Stanley v Powell Judgement

The court held that the injury was accidental and that the defence of an inevitable accident was available. Since the injury was not caused by the defendant’s negligence or intentional act, the defendant was not liable for the plaintiff’s injury. The judgement in favour of the defendant was upheld.

The court considered the circumstances of the case and found that the injury was accidental. There was no evidence to suggest that the defendant was acting negligently when he fired the gun. The defence of inevitable accident applied in this case, as the injury was not caused by the defendant’s negligence or intentional act.

Stanley v Powell Outcome

The court ruled in favour of the defendant, holding that he was not liable for the plaintiff’s injury. The judgement of the lower court was upheld and the plaintiff’s claim was dismissed.

Significance of Stanley v Powell Judgement

Stanley v. Powell is a significant case in tort law as it establishes the defence of inevitable accidents in cases where the injury is accidental and not caused by the defendant’s negligence or intentional act. It clarifies that a defendant cannot be held liable for injuries that are truly accidental and not the result of any wrongful conduct on their part.