1 Q.B. 518 (1964).

Defendant’s employee negligently allowed an asbestos cement cover to slip into a vat of hot sodium cyanide.  The foreseeable risk was injury from splashing liquid, but there was little splash and no one was injured.

However, soon thereafter the cover reacted unforeseeably with the liquid to cause an explosion, which flung molten cyanide into the air.  Some of the liquid fell onto Plaintiff, causing injuries.

The trial court allowed recovery, and Plaintiff’s counsel argued on appeal that the accident simply involved a variant of the foreseeable risk of escaping hot liquid — a sort of delayed splash.

The appellate court ruled, however, that the explosion introduced a new and unexpected risk, which resulted in liquid being hurled a far greater distance (to hit Plaintiff) than ordinarily splashing would have done.

Defendant’s negligence, therefore, was not a proximate cause of Plaintiff’s injuries.

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