Wieland v Cyril Lord Carpets [1969] 3 All E.R. 1006

The claimant suffered an injury through the defendant's negligence and had to wear a surgical collar during recovery. She normally wore bifocal spectacles, but the collar restricted the head movements needed to use them effectively. While negotiating stairs with that limitation, she fell and sustained further injuries. She sought to include the consequences of the second fall in her damages claim against the original defendant. The issue was whether the impaired ability to manage an ordinary activity remained a consequence of the first injury, or whether descending the stairs was an independent intervention.

• Was C’s further injuries a reasonably foreseeable consequence of the injury caused by D’s negligence?
• Did C’s act in descending the stairs constitute an intervening act that broke the chain of causation stemming from D’s negligence?

The claimant recovered for the further injury. The restriction caused by the surgical collar affected her ability to use her spectacles and negotiate the stairs, linking the later fall to the original actionable injury. Her conduct was not treated as an unreasonable independent intervention breaking the chain. The court considered it sufficient that an injury could generally impair a person's capacity to cope with ordinary incidents of life and thereby lead to another injury. It did not require foresight of every detail involving the collar, spectacles and staircase. Whether a later accident is attributable to the first injury remains a question on the facts, rather than an automatic extension of liability.

Damages may include a later injury caused by the claimant's reduced ability to cope with ordinary activities following the original injury. In Wieland, reasonable use of stairs while affected by a surgical collar did not break the causal chain; foreseeability did not require the exact sequence to be anticipated.

Wieland illustrates continuing responsibility during a claimant's recovery, including effects of treatment. Compare McKew, where the reasonableness of the claimant's response produced a different result, and Spencer, where shared responsibility reduced damages without breaking causation. The connecting feature is not merely that two accidents happened to the same person. The first injury must contribute to the second, and the claimant's intervening conduct must be assessed in context. The precise mechanics of the later mishap need not be predicted in advance.