Corr v IBC Vehicles [2008] UKHL 13; [2008] 1 AC 884
Facts
Corr, V, whilst working as a maintenance engineer for the IBC Vehicles, D, suffered severe head injuries by one of the machines The V suffered from PTSD, anxiety, and depression following lengthy reconstructive surgery due to the head injuries, and eventually committed suicide The V’s wife, C, brought an action against the D, suing them for their negligence which caused her husband’s death The D admitted their fault and thus the C was awarded some damages however the judge dismissed her fatal accident claim by believing that the suicide was not reasonably foreseeable by the D C appealed and the Court of Appeal allowed it against the judge’s previous dismissal; D’s then appealed this decision
Legal Issue
- Did it matter that the V had consciously and by his own volition committed suicide, or was this still linked with what the D’s negligence caused?
- In other words, was the chain of causation broken at any time, taking the blame away from the D?
Held
The House of Lords dismissed the employer's appeal. The severe depression arose from the workplace injury and impaired Mr Corr's ability to make reasoned decisions. His suicide was therefore not treated as a free, informed intervention breaking the causal chain. Psychological injury fell within the employer's duty, and the subsequent death was a consequence of the illness caused by the tort. The claimant still had to establish that causal sequence; proving depression alone was not sufficient. The court also rejected voluntary acceptance of the risk as a complete defence on these facts. The decision depends on the relationship between the accident, illness and death.
⭐ Legal Principle
Suicide does not necessarily break the chain of causation where tortiously caused psychiatric illness substantially impairs the injured person's judgment and leads to the death. Liability still requires a causal connection; the mere occurrence of depression after an accident is insufficient.
Significance
Corr avoids an automatic rule that a deliberate physical act must be a legally independent choice. The mental illness caused by the workplace accident was central to understanding the later conduct. Compare Reeves, where the defendant's duty specifically concerned preventing suicide, while Corr concerned psychiatric consequences of an earlier injury. Both require a precise account of the duty and causal evidence rather than assumptions about voluntariness based solely on the form of the final act.
Common exam questions about this case
Why was the suicide not a novus actus interveniens?
It resulted from severe depression caused by the accident, which impaired Mr Corr's capacity for informed judgment. The court therefore did not treat it as an independent decision by a person unaffected by the defendant's wrong. The causal assessment considered the illness and its effects, not simply the deliberate mechanics of the act.
Was showing accident-related depression enough without more?
No. The claimant needed the causal connection between the accident, the psychiatric illness and the death. Corr does not make every employer responsible for any later suicide following workplace injury. Its conclusion depended on accepted evidence about the severe illness and how it affected Mr Corr's conduct.
How is Reeves different?
Reeves concerned a duty to take reasonable care to prevent a known suicide risk in custody. Corr concerned suicide arising from psychiatric illness caused by an earlier workplace accident. Both reject simplistic intervention arguments, but the scope of the duty and the route to causation differ.