[1961] App. Cas. 388, 423 (P.C. 1961).
One-Sentence Takeaway: Consequential damages in tort are subject to a foreseeability limitation.
Defendant negligently spilled a ship’s fuel oil in the harbor. The spill was negligent because the oil might cause a small amount of damage by fouling the dockyard and surrounding ships. The high flash point of the oil made it unlikely, however, that the oil would ignite and cause more extensive fire damage. When the oil ignited and destroyed Plaintiff’s dock, Defendant was not held liable for the fire damage because it was not foreseeable.